Interpretation Response #02-0110 ([ExxonMobil Chemical Company, Intermediates, Synthetics Product Stewardship] [Ronald J. Stokes])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: ExxonMobil Chemical Company, Intermediates, Synthetics Product Stewardship
Individual Name: Ronald J. Stokes
Location State: NJ Country: US
View the Interpretation Document
Response text:
Jul 15, 2002
Mr. Ronald J. Stokes Reference No. 02-0110
ExxonMobil Chemical Company
Intermediates Synthetics Product Stewardship
P.O. Box 3140
Edison, New Jersey 08818
Dear Mr. Stokes:
This is in response to your April 1, 2002, letter regarding the applicability of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180), pertaining to manufacturer's and/or test markings on DOT specification as UN standards for non-bulk single and combination packaging for non-regulated materials.
The HMR, at 49 CFR § 173.22 (a)(l)(2), specify that except as otherwise provided in this part, a person may offer a hazardous material for transportation in a packaging or container required by this part only accordance with the following. The person shall class and describe the hazardous material in accordance with parts 172 and 173, of the HMR.
In addition, the person shall determine that the packaging or container is an authorized packaging, including part 173 requirements, and that it has been manufactured, assembled, and marked in accordance with section 173.7(a) and parts 173, 178, or 179 of this subchapter. Non-regulated materials and materials not meeting the definition of a hazardous material, hazardous substance or hazardous waste in accordance with § 171.8, are not subject to the requirements in 49 CFR. Your questions are answered as follows:
Question:
Can non-regulated material be shipped in a non-bulk single package marked with a DOT specification and/or UN standard?
Answer: Yes.
Question: Can non-regulated material be shipped in a non-bulk combination package marked with a DOT specification and/or UN standard ?
Answer: Yes.
Question: If a different (non-tested) inner receptacle is used in a non-bulk combination package must the DOT specification and/or UN standard be removed (covered) prior to actual shipment?
Answer: No. Specification markings are not required to be removed for the combination packaging described in your scenario.
I hope this information is helpful. Please contact us if you require additional assistance.
Sincerely,
Delmer F. Billings
Chief, Standards Development
Office of Hazardous Materials Standards
171.2(c)
178.2