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

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.


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


Regulation Sections

Section Subject
173.156 Exceptions for limited quantity and ORM