Interpretation Response #14-0022 ([LANXESS Corporation] [Ms. Cyndi Fink])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: LANXESS Corporation
Individual Name: Ms. Cyndi Fink
Location State: PA Country: US
View the Interpretation Document
Response text:
April 24, 2014
Ms. Cyndi Fink
Distribution Safety Manager
LANXESS Corporation
111 RIDC Park West Drive
Pittsburgh, PA 15275
Ref. No. 14-0022
Dear Ms. Fink:
This responds to your January 16, 2014 request for clarification on transporting marine pollutants under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if placards must be removed from containers containing non-bulk packages of marine pollutants transported using the exception in § 171.4.
In accordance with § 171.4, non-bulk packages of marine pollutants being transported by highway, rail, or aircraft are not subject to the HMR. In your incoming letter, you note that a previous interpretation (Ref. No. 01-0288) states “when utilizing the § 171.4 exception markings that were required to be affixed to the packages for transportation by vessel need not be removed or covered for subsequent transportation by other modes.” You ask if one is required to remove placards from a shipping container when such a shipping container is transported under the exception provided in § 171.4.
The exception in § 171.4 does not require you to remove the marine pollutant markings by highway, rail, or aircraft.
I hope this answers your inquiry. If you need additional assistance, please call this office at (202) 366-8553.
Sincerely,
Robert Benedict
Chief, Standards Development Branch
Standards and Rulemaking Division
171.4
Regulation Sections
| Section | Subject |
|---|---|
| 171.4 | Marine pollutants |