Use of Canadian Special Permits in the US

This is in reference to my letter of March 13, 1984, in response to your letter of February 24, 1984, relative to the transportation of hazardous materials in the United States in packagings authorized by Canadian Transport Commission (CTC) special permits when the packagings are filled in the United States. My March 13, 1984, letter was incomplete and is replaced by this letter.

A packaging, except a cylinder, authorized by a CTC special permit may be shipped in the United States and to its destination by rail. Such a packaging may not be filled and reshipped in the United States unless its use is authorized in a Department of Transportation regulation or exemption. This interpretation is based on 49 CFR 173.8(b).

With specific reference to CTC SpeciaI Permit 1870 authorizing sodium chlorate, UN 1495 to be transported by railcar in a flexible intermediate bulk container, DOT exemption E-9110 contains corresponding provisions.