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Interpretation Response #00-0170


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

Interpretation Response Details

Response Publish Date: 10-10-2000
Company Name: Stonhard, Inc.    Individual Name: Mr. Walter D. Toomer, CHMM
Location state: NJ    Country: US

View the Interpretation Document


Response text:

October 10, 2000

Mr. Walter D. Toomer, CHMM                Reference. No. 00-0170
Manager, Regulatory Affairs
Stonhard, Inc.
One Park Avenue
Maple Shade, NJ 08052

Dear Mr. Toomer:

This is in response to your June 8, 2000 letter requesting a definition of  "Paint." You also asked whether the gross mass of inner packagings must be shown on the shipping paper for vessel shipments.

You are correct, "Paint" is not defined in 49 CFR 171.8. Section 173.173 identifies "Paint" as the proper shipping name for "paint, lacquer, enamel, stain, shellac, varnish, liquid aluminum, liquid bronze, liquid gold, liquid wood filler, and liquid lacquer base." The proper shipping name "Paint-related material" describes paint thinning, drying, reducing or removing compounds.  If a more specific description is listed in the §172. 1 01 Hazardous Materials Table, that description must be used.

In response to the second question, the shipping paper entry required by §172.203(i)(3) for the gross mass of each type of package or the individual gross mass of each package for vessel shipments applies to the outside package; which in your case is the combination package.  The gross mass of individual inner packagings is not a required entry.

I hope this satisfies your request,

Sincerely,

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

173.173


Regulation Sections

Section Subject
§ 173.173 Paint, paint-related material, adhesives, ink and resins.