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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #00-0244 ([Infotrac, Inc.] [Mr. Jason Kob])

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

Interpretation Response Details

Response Publish Date:

Company Name: Infotrac, Inc.

Individual Name: Mr. Jason Kob

Location State: FL Country: US

View the Interpretation Document

Response text:

March 7, 2001

Mr. Jason Kob                Ref No. 00-0244
Infotrac, Inc.
200 N. Palmetto Street
Leesburg, Florida 34748

Dear Mr. Kob:

This responds to your September 7, 2000 letter concerning requirements for shipping a consumer commodity under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Specifically, you ask about requirements for repackaging consumer commodities.

Your company is a distribution center for retail stores and distributes hazardous materials, "Consumer commodity, ORM-D," and non-hazardous materials.  You want to break down the strong outer packaging in which the ORM-D materials were originally transported from the manufacturer and repack the ORM-D materials in strong plastic bins with lids.  The bins would then be shrink-wrapped together on a pallet and transported by private, contract, or common carrier from your distribution center to the retail outlets.  You ask about the HMR requirements that would apply to such shipments.

As specified in §173.156(b), packages of materials described as "Consumer commodity, ORM-D" are not subject to the marking requirements in Subpart D of Part 172, and to the 30 kg (66 pounds) gross weight limitation, when unitized in cages, carts, boxes or similar overpacks, and when offered for transportation or transported by a private or contract motor carrier or a common carrier vehicle under exclusive use for such service, from a manufacturer to a distribution center, from a manufacturer or distribution center to a retail outlet, or return.  The plastic, shrink-wrapped bins containing the consumer commodities conform to the provisions in §173.156(b) and, thus, need not be marked in accordance with §172.312 or §172.316. Further, the bins need not conform to the overpack requirements in §173.25.

I hope this satisfies your inquiry.  If we can be of further assistance, please contact us.


John Gale
Transportation Regulations Specialist
Office of Hazardous Materials Specialist


Regulation Sections

Section Subject
173.156 Exceptions for limited quantity and ORM