Interpretation Response #02-0045 ([HB Fuller Company] [Gene Seco])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: HB Fuller Company
Individual Name: Gene Seco
Location State: MI Country: US
View the Interpretation Document
Response text:
April 26, 2002
Mr. Gene Secor Reference No.: 02-0045
HB Fuller Company
25200 Malvina Avenue
Warren, MI 48089
Dear Mr. Secor:
This is in response to your letter concerning requirements for shipping consumer commodities under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask about the exceptions for ORM-D materials in § 173.156(b)(1). Your questions are paraphrased and answered as follows:
Q1. Are outer packagings of combination packages the same as "boxes" as that term is used in § 173.156(b)(1)(i)?
A1. Yes. The outer packaging of a combination package meets the requirement for "boxes" for the purpose of unitizing under § 173.156(b)(1)(i).
Q2. Are orientation markings required if the inner packagings contain liquid?
A2. No. Packagings transported under § 173.156(b)(1) are excepted from the marking requirements in subpart D of part 172 of the HMR.
Q3. May individual combination packagings containing liquids and marked "Consumer Commodity, ORM-D" be offered for transportation or must they be in another box or overpack?
A3. Individual combination packages containing Class 8 (corrosive) materials, as described in your letter, may be offered for transportation provided they also meet the requirements in § 173.156(b)(1)(ii) and (iii), or they may be offered in conformance with the provisions of § 173.154(c).
I hope this satisfies your inquiry. If we can be of further assistance, please contact us.
Sincerely,
John A. Gale
Transportation Regulations Specialist
Office of Hazardous Materials Standards
173.156
Regulation Sections
| Section | Subject |
|---|---|
| 173.156 | Exceptions for limited quantity and ORM |