Interpretation Response #04-0044 ([Reagent Chemical & Research, Inc.] [Mr. Robert Dritschel])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Reagent Chemical & Research, Inc.
Individual Name: Mr. Robert Dritschel
Location State: NJ Country: US
View the Interpretation Document
Response text:
Mar 18, 2004
Mr. Robert Dritschel Reference No. 04-0044
Reagent Chemical & Research, Inc.
Manager - Technical Services
124 River Road
Middlesex, NJ 08846
Dear Mi. Dritschel:
This is in response to your letter dated February 26, 2004 regarding the transportation and handling of sample containers of "Hydrochloric acid solution, UN1 789, Class 8, PG II" under the Hazardous Materials Regulations (HMR: 49 CFR Parts 171-180). Specifically, you ask if this material could be transported as a limited quantity or as a material of trade. You want to transport the sample in a combination packaging consisting of an inner packaging, absorbent material, and outer PVC sleeve. Further, you state that the PVC sleeve will be fastened to the dolly leg subframe of the bulk trailer.
From the information you provided it is our opinion that your "Hydrochloric acid solution, UN1789, Class 8, PG II" is eligible for both the limited quantity exception and the materials of trade exception. In order to utilize those exceptions you must adhere to the requirements of § 173.154 and § 173.6, respectively.
I hope this satisfies your request.
Sincerely,
John A. Gale
Chief, Standards Development
Office of Hazardous Materials Standards
173.154
Regulation Sections
| Section | Subject |
|---|---|
| 173.154 | Exceptions for Class 8 (corrosive materials) |