Interpretation Response #01-0198 ([Aceto Corporation] [Mr. Simone A. Yearwood])

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

Interpretation Response Details

Response Publish Date: 08/16/2001

Company Name: Aceto Corporation

Individual Name: Mr. Simone A. Yearwood

Location State: NY Country: US

View the Interpretation Document

Response text:

August 16, 2001

Mr. Simone A. Yearwood                           Ref. No. 01-0198
Aceto Corporation
One Hollow Lane
Lake Success, NY 11042-1215

Dear Mr. Yearwood:

This is in response to your July 23, 2001 letter concerning marking UN specification drums under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Specifically, you wish to ship Pyridine in incorrectly marked UN specification drums.

You may not transport Pyridine in incorrectly marked UN packagings.  However, you may correct the UN specification marking (in this case, changing the “Z” marking to a “Y” marking) if you posses the valid test results that indicate the drum meets the  “Y” specification criteria.  Since your company is a different company than the company that originally marked the drums, you may not use the symbol representing the original company unless specific permission and arrangements, such as a written agreement, exist between your company and the original company.  Enclosed is a previously issued letter from this Office that further clarifies the UN marking requirements.

I hope this satisfies your request.

Sincerely,

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

178.503

Regulation Sections