Interpretation Response #06-0032 ([Mr. Thomas Richichi])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name:
Individual Name: Mr. Thomas Richichi
Location State: DC Country: US
View the Interpretation Document
Response text:
Mar 24, 2006
Mr. Thomas Richichi Reference No. 06-0032
1350 I Street, N.W.
Suite 700
Washington, D.C. 20005
Mr. Richichi:
This is in response to your letter regarding the assignment of packing group and hazard zones for Division 6.1 materials under § 173.133(a) of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You reference a January 29, 1997 letter of interpretation from Delmer F. Billings to James R. Barrett in which we indicated that a material with a low vapor pressure such that it can not readily vaporize or mist in transportation is not required to be evaluated against the inhalation exposure criteria in § 173.133(b). Specifically, you request confirmation that the letter applies to the packing group and hazard zone assignment criteria in § 173.133(b) and the criteria in § 173.133(a).
The January 29, 1997 letter you reference provides general classification procedures (i.e., determination of hazard class, hazard zone, packing group) for Division 6.1 materials. Therefore, the letter applies to all of § 173.132 and 173.133, as applicable, including the packing group and hazard zone criteria in paragraphs (a) and (b) of § 173.133.
I hope this information is helpful. Please contact us if you require additioiv4 assistance.
Sincerely,
John A. Gale
Chief Standards Development
Office of Hazardous Materials Standards
173.133(a)