Interpretation Response #02-0157 ([Gislason & Hunter LLP] [Gary W. Koch])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Gislason & Hunter LLP
Individual Name: Gary W. Koch
Location State: MN Country: US
View the Interpretation Document
Response text:
Jul 24, 2002
Mr. Gary W. Koch Reference No. 02-0157
Gislason & Hunter LLP
P.O. Box 458
New Ulm, MN 56073-0458
Dear Mr. Koch:
This responds to your letter dated June 3, 2002, regarding marking and labeling requirements and exceptions for certain explosives under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you request confirmation that your client may reclassify imported packages of shot gun cartridges from Division 1.4S to ORM-D. In addition, you inquire whether these packages may contain multiple (international and domestic U.S.) markings and labels. For international transport, each package of cartridges would be marked "Cartridges, small arms, UN0012" and labeled "1.4S", and for domestic U.S. transport, would be marked "Cartridges, small arms, ORM-D."
As prescribed-in § 173.63(b), small arms cartridges which have been classed as a Division 1.4S explosive may be reclassed, offered for transportation, and transported as ORM-D material when packaged in accordance with § 173.63(b)(2). In addition, the HMR do not prohibit multiple markings and labels on packages when required by authorized regulatory agencies. To maintain the effectiveness of these markings and labels, we suggest that their placement on the package be clearly distinguishable from each other.
I trust this satisfies your inquiry. Please contact us if we can be of further assistance.
Sincerely,
Hattie L. Mitchell
Chief, Regulatory Review and Reinvention
Office of Hazardous Materials Standards
173.63
Regulation Sections
| Section | Subject |
|---|---|
| 173.63 | Packaging exceptions |