The Journal of HazMat Transportation's™ Exclusive Comments on U.S. DOT Letters of Interpretation of the Hazardous Materials Regulations

摘要

The questioner seeks guidance from PHMSA on the culpability of her company when it offers, as the shipper of record, rail tank cars with sulphur residues on the outside jacket. Perhaps you have seen tank cars carrying molten sulphur with solidified sulphur on the tank car outer surface. It is no doubt hard to remove solidified residues. How hazardous are these sulphur residues when sulphur, does not actually meet the criteria for Division 4.1, is regulated largely due to it being transported in a molten state (e.g., note that nonbulk packages of sulphur of a defined particle shape are not subject to the regulations; see special provision 30) and when adhering to the outer surface as a solid poses no definable risk for a hazardous material under the HMR?