Interpretation Response #08-0002 ([Kajuligan Corporation] [Mr. Clifford E. Croft])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Kajuligan Corporation
Individual Name: Mr. Clifford E. Croft
Location State: IL Country: US
View the Interpretation Document
Response text:
February 21, 2008
Mr. Clifford E. Croft
Director, Regulatory Compliance
Kajuligan Corporation
316 Crescent Place
Geneva, IL 60134
Reference No. 08-0002
Dear Mr. Croft:
This responds to your letter, postmarked December 14, 2007, concerning requirements in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to small quantity shipments. Specifically, you ask about requirements applicable to packages prepared in accordance with § 173.4 and overpacked in a fiberboard box. Your questions are paraphrased and answered as follows:
Q1. If packages conforming to the requirements in § 173.4 are overpacked in a fiberboard box, must the overpack successfully pass the package testing requirements specified in § 173.4(a)(6)?
A1. No. The package testing requirements apply to the packaging configurations specified in § 173.4.
Q2. If packages conforming to the requirements in § 173.4 are overpacked in a fiberboard box, must the overpack be marked "This package conforms to 49 CFR 173.4"? If not, must the overpack be marked "OVERPACK"?
A2. The marking specified in § 173.4 is the shipper"s statement certifying that a package conforms to the requirements set forth in that section. No certification mark is required for the overpack. Further, packages prepared in accordance with § 173.4 are excepted from all other HMR requirements. Thus, the marking requirements in § 173.25 applicable to overpacks do not apply to overpacks containing packages prepared in accordance with § 173.4.
Q3. May the overpack exceed the 29 kg gross weight limit specified in § 173.4(a)(8)?
A3. Yes. The weight limitation applies to individual packages prepared in accordance with § 173.4.
I hope this satisfies you request.
Sincerely,
Hattie L. Mitchell, Chief
Regulatory Review and Reinvention
Office of Hazardous Materials Standards
173.4
Regulation Sections
| Section | Subject |
|---|---|
| 173.4 | Small quantities for highway and rail |