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Interpretation Response #00-0108 ([Hazmateam, Inc.] [Mr. Paul J. Dambek])

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

Interpretation Response Details

Response Publish Date:

Company Name: Hazmateam, Inc.

Individual Name: Mr. Paul J. Dambek

Location State: CT Country: US

View the Interpretation Document

Response text:

June 6, 2000

Mr. Paul J. Dambek                Ref.  No. 00-0108
Hazmateam, Inc.
24 Mystic Hill Road
Mystic, CT 06355

Dear Mr. Dambek:

This is in response to your letter requesting clarification under the Hazardous Materials Regulations (HMR;49 CFR Parts 171-180) pertaining to the use of the entry "Polyester resin kit,"  UN3269.  Specifically, you ask whether your material and packaging meets the requirements under Special Provision 40 and whether your inner packaging consisting of two separate reservoirs would be considered two separate inner receptacles.

You state that the kit contains two separate materials consisting of a methyl methacrylate adhesive which is a Class 3, Packing Group III and dibenzoyl peroxide, type E, PG II which is an organic peroxide activator in solid form.  Provided the organic peroxide does not require temperature control, its maximum quantity does not exceed one pound per inner packaging and the two materials will not interact dangerously in the event of leakage, your material meets the requirements for Special Provision 40.

With regard to the packaging you sent us, it is the opinion of this Office that it is two separate receptacles which are attached.  Provided the inner receptacles are placed in an outer specification package as specified in §173.2.25, your packaging is authorized for the entry "Polyester resin kit."

I hope this information is helpful.  Please contact this office if you need additional assistance.


Hattie L. Mitchell, Chief
Regulatory Review and Reinvention
Office of Hazardous Materials Standards

172.101 (p)

Regulation Sections

Section Subject
172.101 Purpose and use of hazardous materials table