Interpretation Response #04-0084 ([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: 04/15/2004

Company Name: Reagent Chemical & Research, Inc.

Individual Name: Mr. Robert Dritschel

Location State: NY Country: US

View the Interpretation Document

Response text:

Apr 15, 2004

Mr. Robert Dritschel                Reference No. 04-0084
Reagent Chemical & Research, Inc.
Manager - Technical Services
124 River Road
Middlesex, NJ 08846

Dear Mr.  Dritschel:

This is in response to your letter dated April 2, 2004 and subsequent telephone conversation with Ben Supko of my staff regarding the transportation and handling of sample containers of “Hydrochloric acid solution, UN1789, 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”, packaged and transported as described above, 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