Interpretation Response #15-0050 ([URS Corporation] [Mr. Andrew Romach])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: URS Corporation
Individual Name: Mr. Andrew Romach
Location State: NC Country: US
View the Interpretation Document
Response text:
June 8, 2015
Mr. Andrew Romach
Regulatory Compliance Manager
URS Corporation
1600 Perimeter Park Dr.
Morrisville, NC 27560
Reference No. 15-0050
Dear Mr. Romach:
This is in response to your January 8, 2015 e-mail requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to use of the small quantities exception. Specifically, you ask whether a hazardous material with the word "None" in Column 8A of the § 172.101 Hazardous Materials Table (HMT) is eligible for the small quantities exception in § 173.4. You provide the example of "UN2734, Amines, liquid, corrosive, flammable, n.o.s., 8 (3), PGII."
Provided all the conditions specified in § 173.4 are met, the answer is yes. Section 172.101(i)(1) states: "Column 8A contains exceptions from some of the requirements of this subchapter. The referenced exceptions are in addition to those specified in subpart A of part 173 and elsewhere in this subchapter. A "None" in this column means no packaging exceptions are authorized, except as may be provided by special provisions in Column 7." Therefore, a "None" in column 8A of the § 172.101 HMT does not affect the eligibility for use of exceptions in Part 173 Subpart A, including the small quantities exception in § 173.4.
I hope this satisfies your request.
Sincerely,
T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division
173.4, 172.101(i)(1), 172.101, 173.4