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Interpretation Response #03-0224 ([ShipMate, Inc.] [Mr. Steven Charles Hunt])

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

Interpretation Response Details

Response Publish Date:

Company Name: ShipMate, Inc.

Individual Name: Mr. Steven Charles Hunt

Location State: CA Country: US

View the Interpretation Document

Response text:

Nov 4, 2003


Mr. Steven Charles Hunt               Reference No. 03-0224

ShipMate, Inc.

18436 Hawthorne Blvd.

Suite 201

Torrance, CA 90504

Dear Mr. Hunt:

This responds to your April 29, 2003 letter concerning hazardous materials transportation security requirements adopted under a final rule published March 25,2003. Specifically, you ask whether the security plan requirements established in the final rule apply to shipments of Class 9 materials (e.g., Air Bag Module, 9, UN3268, ill) when offered for transportation by vessel. It is your understanding that a freight container carrying a hazardous material such as an air bag module, described as an "Air Bag Module, 9, UN3268, TIl, II must be placarded when offered for transportation by vessel even when the freight container carries only one 10-pound fiberboard box.

Your understanding is incorrect. Section 172.514(a) requires a bulk packaging containing a hazardous material to be placarded as specified in §§ 172.504 and 172.505. Section 172.504(f)(9) excepts domestic shipments of Class 9 materials from the placarding requirements. Thus, a placard is not required for domestic shipments of Class 9 materials; however, international shipments of Class 9 materials may need to be placarded in accordance with international regulations. If a CLASS 9 placard is not required for the domestic portion of transportation, the security plan requirements in Subpart I do not apply to such shipments, even if a CLASS 9 placard is required for the international portion of transportation. Note, however,

that a person who offers or transports a Class 9 material in a bulk packaging having a capacity equal to or greater than 13,248 L (3,500 gallons) for liquids or gases or more than 13.24 cubic meters (468 cubic feet) for solids must develop and implement a security plan, irrespective of placarding requirements (see § 172.800(b)(4)).

The HM-232 final rule also includes new security training requirements. Section 172.704(a)(4) requires all hazmat employees, defined in § 171.8 of the HMR, to receive security awareness training. Thus, even though your Class 9 shipments may not be subject to security plan requirements, your hazmat employees must receive security awareness training. We have developed a computer-based security awareness CD-ROM that can be used to satisfy the security awareness training requirements in § 172.704(a)(4). The training CD-ROM is available to the public at no charge; it can be downloaded from our website ( or ordered from our Training and Initiatives Office at 202-366-4900.

I hope this information is helpful. If you have further questions, please do not hesitate to contact this office.



Susan Gorsky, Regulations Officer

Office of Hazardous Materials Standards

Regulation Sections

Section Subject
172.704 Training requirements
172.800 Purpose and applicability