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Interpretation Response #11-0304 ([Dangerous Goods Transport Consulting, Inc.] [Mr. Frits Wybenga])

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date:

Company Name: Dangerous Goods Transport Consulting, Inc.

Individual Name: Mr. Frits Wybenga

Location State: MD Country: US

View the Interpretation Document

Response text:

March 28, 2012

 

 

Mr. Frits Wybenga
President
Dangerous Goods Transport Consulting, Inc.
15108 Red Clover Drive
Rockville, MD 20853

Reference No.: 11-0304

Dear Mr. Wybenga:

This is in response to your December 12, 2011 letter requesting guidance as to whether a recent amendment to Chapter 6.1.1.1(d) of the United Nations Recommendations on the Transport of Dangerous Goods: Model Regulations (UN Model Regulations), approved by the 40th session of the United Nations Subcommittee of Experts on the Transport of Dangerous Goods, may be immediately applied in accordance with the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). The amendment changes the UN Model Regulations to the extent that the 450 liter capacity limitation applies only to liquids, other than combination packagings, and packagings containing solids are only subject to the 400 kg net mass limitation provided in Chapter 6.1.1.1(c).

The codification of this amendment into the HMR will be considered for a future harmonization rulemaking. Until that time, this amendment to the UN Model Regulations cannot be applied to the HMR. However, in accordance with 49 CFR Part 107, an application for a special permit may be submitted, requesting permission to exceed the 450 liter capacity limitation.

I trust this satisfies your inquiry. Please contact us if we can be of further assistance.

Sincerely,

 

Delmer Billings
Senior Regulatory Advisor
Standards and Rulemaking Division
178.516(b)(6)

Regulation Sections