Interpretation Response #09-0257 ([Benjamin Moore & Co.] [Mr. Prokopis Christou])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Benjamin Moore & Co.
Individual Name: Mr. Prokopis Christou
Location State: NJ Country: US
View the Interpretation Document
Response text:
December 3, 2009
Mr. Prokopis Christou, PE, CHMM
Corporate Environmental, Health & Safety Department
Benjamin Moore & Co.
360 Route 206
Flanders, NJ 07836
Ref. No. 09-0257
Dear Mr. Christou:
This responds to your October 29, 2009 request for clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if packaging marked with Special Permit Numbers DOT SP 12749 and DOT SP 13052 pertaining to UN 11G fiberboard intermediate bulk containers (IBCs) may be used to transport non- hazardous materials.
The answer is yes. The prohibited marking requirements in § 172.303 of the HMR do not require removal or obliteration of the special permit number from the packaging, even when the packaging is not being used under the terms of the special permit. However, in order to minimize confusion or frustration of the shipment, you may wish to cover or obliterate the special permit number markings when the packaging is not being used under the terms of the special permit.
I hope this answers your inquiry. If you need additional assistance, do not hesitate to contact this Office.
Sincerely,
Charles E. Betts
Chief, Standards Development
Office of Hazardous Materials Standards
172.303
Regulation Sections
| Section | Subject |
|---|---|
| 172.303 | Prohibited marking |