Interpretation Response #01-0124 ([Den Plus Inc.] [Dr. Shuojia Dong])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Den Plus Inc.
Individual Name: Dr. Shuojia Dong
Location State: AL Country: US
View the Interpretation Document
Response text:
June 1, 2001
Dr. Shuojia Dong Ref. No. 01-0124
Den Plus Inc.
4235 Beaconsfield
Montreal, Quebec
CANADA, H4A 2H4
Dear Dr. Dong:
This is in response to your letter dated May 8, 20011 requesting clarification on the use of the limited quantity exceptions in the Hazardous Materials Regulations (HMR- 49 CFR Parts 171-180). You state you are shipping packages of dental acrylic monomer under the description "Methyl methacrylate monomer, inhibited, 3, UN 1247, PG II". Specifically, you request confirmation of your understanding of the limited quantity provision (§ 113J50) specified for this entry in column 8A of the Hazardous Materials Table (§ 172.101).
You are correct in your understanding of the limited quantity exceptions for Class 3 (flammable liquids) as provided in § 173.150. Flammable liquids in "Packing Group II" may be packed in inner packagings not over 1.0 L net capacity each, packed in strong outer packagings. The limited quantity provisions for Class 3 materials in § 173.150 authorize exceptions from labeling (except when transported by air), placarding, and from specification packaging requirements when packaged in combination packagings according to provisions in § 173.150(b). Each package must conform to general packaging requirements in Part 173, Subpart B, and may not exceed 30 kg gross weight.
Each person who offers for transportation a hazardous material in a non-bulk packaging shall mark the package with the proper shipping name and identification number for the material as shown in the Hazardous Materials Table (§ 172.30i,(a)). under § 172.312(c), package orientation markings are not required on packages containing flammable liquids in inner packagings of 1.0 L or less prepared in accordance with § 173.150(b) or (b), except when offered or intended for transportation by aircraft.
The shipping paper you provided is not in accordance with the requirements of Part 172, Subpart C. The shipping description of a hazardous material on the shipping paper, must include the proper shipping name, hazard class, identification number, and packing group prescribed for the material in the Hazardous Materials Table, with no additional information interspersed 172.202). For example: "Methyl methacrylate monomer, inhibited, 3, UN 1247, PG II." The total quantity (by net or gross mass, capacity, or as otherwise appropriate), including the unit of measurement, of the hazardous material cove , red bv the description must be shown either before or after the, basic description. The description for a material offered for transportation as "limited quantity," as authorized by the HMR, must include the words "Limited Quantity" or " Ltd Qty" following the basic description (§ 172.203(b)). The required shipping description on a shipping paper and all copies there of used for transportation purposes, must be legible and printed in English 172.201 (a) (2).
I hope this satisfies your request.
Sincerely,
Transportation Regulations Specialist
Office of Hazardous Materials Standards
173.150
Regulation Sections
| Section | Subject |
|---|---|
| 173.150 | Exceptions for Class 3 (flammable and combustible liquids) |