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Why Doesn’t a Bulk Packaging Include a Barge or Vessel?

Why Doesn’t a Bulk Packaging Include a Barge or Vessel?

A Bulk Packaging, defined at 49 CFR 171.8:  “Means a packaging, other than a vessel or a barge, including a transport vehicle or freight container, in which hazardous materials are loaded with no intermediate form of containment. A Large Packaging in which hazardous materials are loaded with an intermediate form of containment, such as one or more articles or inner packagings, is also a bulk packaging. Additionally, a bulk packaging has:

  1. A maximum capacity greater than 450 L (119 gallons) as a receptacle for a liquid;
  2. A maximum net mass greater than 400 kg (882 pounds) and a maximum capacity greater than 450 L (119 gallons) as a receptacle for a solid; or
  3. A water capacity greater than 454 kg (1000 pounds) as a receptacle for a gas as defined in §173.115 of this subchapter.”

Simple enough, but why is it that a vessel or barge is specifically excluded from the definition of a Bulk Packaging?

Before we get to the answer, let’s make sure we understand the terms, both of which are defined at 49 CFR 171.8:

  • “Vessel includes every description of watercraft, used or capable of being used as a means of transportation on the water.”
  • “Barge means a non-self propelled vessel.”

The answer, is that any material, including a hazardous material, loaded directly into the hold of a vessel or barge is subject to the regulations of the US Coast Guard and not the Pipeline and Hazardous Materials Administration (PHMSA) of the US DOT and therefore not subject to the Hazardous Material Regulations.

The transportation of hazardous materials involves many different methods (air, water, highway, rail) each of which is subject to the regulations of the PHMSA.  But other Federal agencies have their own authority and their own regulations that may impact the shipment as well.  Learn what you need to know about the transportation of hazardous materials at my training, either On-Site or Public Workshop/Open Enrollment.  Contact me for a free consultation on your training needs.