Interpretation Response #03-0179 ([Ray-Vin.Com] [Mr. Raymond V. Brandes])

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

Interpretation Response Details

Response Publish Date: 10/22/2003

Company Name: Ray-Vin.Com

Individual Name: Mr. Raymond V. Brandes

Location State: FL Country: US

View the Interpretation Document

Response text:

Oct 22, 2003

Mr. Raymond V. Brandes               Ref. No. 03-0179
Ray-Vin.Com
1844 Mt. Cello Rd.
Marianna, FL 32448-5365

Dear Mr. Brandes:

This is in response to your letter dated July 8, 2003 and subsequent telephone conversation with a member of my staff, concerning the regulation of calcium carbide pursuant to the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Your questions are paraphrased and answered as follows:

Q1. Must calcium carbide (Division 4.3, UN1402, Packing Group II), shipped as a limited quantity, display a -"Dangerous When Wet" placard?

A1. No. Section 173.151(d) states that limited quantities of Division' 4.3 solids in' Packing Groups. II and III are excepted from labeling, unless offered for transportation or transported, by aircraft, specification packaging if packaged in accordance with the combination packaging provisions, and placarding requirements. The combination packaging provisions state that Division 4.3 solids in Packing Group II must be contained in inner packagings not over 0.5kg (1.1 pound) net capacity each packed in strong outer packagings.

Q2. If a shipment qualifies as a limited quantity per exceptions in 173.151(d), is it still a hazardous material?

A2. Yes.

Q3~ If a shipment qualifies as a limited quantity per exceptions in 173.151(d), can it be loaded on passenger aircraft?

A3. As shown' in the Hazardous Materials Table (§ 172.101), calcium carbide in Packing Group II is not forbidden from being loaded on passenger aircraft, but the net quantity per package is limited to 15 kg. Section 173.151(d) states that limited quantities of Division 4.3 solids in Packing Groups II and III are excepted from labeling as long as it is not offered for transportation or transported by aircraft. This language does not preclude the material from being loaded on passenger aircraft, but it does require that if the material is being offered for transportation or transported by air that it comply with the appropriate labeling requirements for Division 4.3 Packing Group II materials. In addition, the packaging requirements specified in 173.27 apply to shipment by aircraft.

Q4. What, if any, requirements are there for labeling the internal package?'

A4. The required labels and markings must be displayed on the outside of the package.

I hope this satisfies your request.

Sincerely,

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

Regulation Sections