USA Banner

Official US Government Icon

Official websites use .gov
A .gov website belongs to an official government organization in the United States.

Secure Site Icon

Secure .gov websites use HTTPS
A lock ( ) or https:// means you’ve safely connected to the .gov website. Share sensitive information only on official, secure websites.

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

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.



John A. Gale
Transportation Regulations Specialist
Office of Hazardous Materials Standards


Regulation Sections

Section Subject
173.25 Authorized packagings and overpacks