Interpretation Response #01-0149 ([Epichem Incorporated] [Mr. Brian McCarthy])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Epichem Incorporated
Individual Name: Mr. Brian McCarthy
Location State: MA Country: US
View the Interpretation Document
Response text:
August 9, 2001
Mr. Brian McCarthy Ref. No. 01-0149
Administrator, Shipping and Transportation
Epichem Incorporated
P.O. Box 8230
Haverhill, MA 01835
Dear Mr. McCarthy:
This responds to your June 7, 2001 letter requesting clarification of shipments of Division 6.1 poison materials with foodstuffs under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically you ask if your packaging meets the exception provided by § 173.25(c) for poisonous materials that may be transported in the same motor vehicle with foodstuffs.
The answer is no. Your exemption specifies that your material must be packaged in a UN 1A2 drum. The drum is thus the packaging, and not an overpack. You state that you overpack your drum in a UN 4G box. The provisions of § 173.25(c) require that the packaging must be overpacked in a UN 1A2, 1B2, or 1N2 drum tested and marked for a Packing Group 11 or higher performance level.
I trust this satisfies your request. If we can be of further assistance, please contact us.
Sincerely,
John A. Gale
Transportation Regulations Specialist
Office of Hazardous Materials Standards
173.25
Regulation Sections
| Section | Subject |
|---|---|
| 173.25 | Authorized packagings and overpacks |