Interpretation Response #00-0218 ([KWS Training, Inc.] [Mr. Ken Sumner])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: KWS Training, Inc.
Individual Name: Mr. Ken Sumner
Location State: NC Country: US
View the Interpretation Document
Response text:
March 2, 2001
Mr. Ken Sumner Reference No. 00-0218
President, KWS Training, Inc.
P.O. Box 562
Carrboro, NC 27510
Dear Mr. Sumner:
This is in response to your letter concerning the emergency response requirements in 49 CFR Part 172, Subpart G, for a "Consumer commodity, ORM-D." You asked why a consumer commodity is excepted from having to meet the emergency response requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180), but must meet these same requirements under State Variation US 12 of the International Civil Aviation Organization's Technical Instructions for the Transport of Dangerous Goods by Air (the ICAO Technical Instructions).
Materials that are correctly described as consumer commodity and classed as ORM-D, as provided by the HMR, or Class 9, as provided by the ICAO Technical Instructions, are not required to meet the emergency response information requirements. Voluntary compliance with this change was permitted after August 18, 2000 (65 FR 50450, RSPA Docket No. 99-6213, HM-218, copy enclosed). This authorization in the HMR serves as a Competent Authority approval for the ICAO Technical Instructions. Also, State Variation US 12 was revised to include this change, which will appear in the 2001-2002 edition of the ICAO Technical Instructions.
I hope this satisfies your request.
Sincerely,
Hattie L. Mitchell
Chief, Regulatory Review and Reinvention
Office of Hazardous Materials Standards
172.600
Regulation Sections
| Section | Subject |
|---|---|
| 172.600 | Applicability and general requirements |