Interpretation Response #18-0094
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: DG Advisor, LLC
Individual Name: Ben Barrett
Location State: WY Country: US
View the Interpretation Document
Response text:
February 25, 2019
Ben Barrett
DG Advisor, LLC
P.O. Box 248
Dubois, WY 82513
Reference No. 18-0094
Dear Mr. Barrett:
This letter is in response to your June 20, 2018, email and letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the shipment of hazardous materials in the same overpack together with materials not meeting the definition of a hazardous material.
We have paraphrased and answered your questions as follows:
Q1. You ask if a non-hazardous material can be placed in an overpack that contains a hazardous material package.
A1. The answer is yes. The HMR do not prescribe requirements or limitations for non-hazardous material packed in an overpack; therefore, there is no prohibition from including hazardous and non hazardous material in an overpack together.
Q2. You ask if the non-hazardous material must be considered when determining the applicability of the placarding exception in § 172.504(c).
A2. The answer is no. The weight of non-hazardous material is not included in the determination of aggregate gross weight of the hazardous material for the purposes of the placarding exception for non-bulk packages found in § 172.504(c).
I hope this information is helpful. Please contact us if we can be of further assistance.
Sincerely,
Dirk Der Kinderen
Chief, Standards Development Branch
Standards and Rulemaking Division
172.504(c)
Regulation Sections
| Section | Subject |
|---|---|
| 172.504 | General placarding requirements |