Interpretation Response #05-0062 ([Mallinckrodt Baker, Inc.] [Ms. Dianna F. Lee])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Mallinckrodt Baker, Inc.
Individual Name: Ms. Dianna F. Lee
Location State: NJ Country: US
View the Interpretation Document
Response text:
May 6, 2005
Ms. Dianna F. Lee Reference No. 05-0062
Mallinckrodt Baker, Inc.
600 N. Broad Street
Phillipsburg, NJ 08865
Dear Ms. Lee:
This responds to your November 3, 2004 letter and March 18, 2005 fax requesting clarification on the labeling requirements for 'Methanol' when shipped domestically and internationally under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171- 180). Specifically, you ask whether it is permissible to label the package in compliance with international requirements when shipped domestically only.
The answer is yes. As your letter notes, the: Hazardous Materials Table (HMT) includes two entries for methanol, one for international transportation and one for domestic transportation. The two entries are identical, except that the international entry requires a subsidiary hazard Division 6.1 label, and the domestic entry does not. In accordance with § 172.101(b)(3) and (b)(5), you may use either the international or domestic entry in the HMT for domestic transportation of methanol.
I hope this answers your inquiry.
Sincerely,
Chief, Standards Development
Office of Hazardous Materials Standards
172.101, 172.419