Interpretation Response #04-0013 ([Keller and Heckman LLP] [Mr. Michael P. Morrone])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Keller and Heckman LLP
Individual Name: Mr. Michael P. Morrone
Location State: DC Country: US
View the Interpretation Document
Response text:
Feb 13, 2004
Mr. Michael P. Morrone Reference No. 04-0013
Keller and Heckman LLP
1001 G St., N.W., Suite 500 West
Washington, D.C. 20001
Dear Mr. Morrone:
This is in response to Your January 13, 2004 letter requesting clarification regarding the applicability of the materials of trade exceptions under the Hazardous Materials Regulations (HMR; 49 CPR Parts 171-180). Specifically, you ask us to confirm your understanding that your client"s (Selective Micro Technologies) cleaning products, as described in your letter, may be offered for transportation and transported under the materials of trade exceptions in § 173.6. You state that all applicable requirements in § 173.6 are met. You"re requested confidential treatment for certain information contained in your letter is granted.
Your understanding of the requirements for the materials of trade exceptions and the provisions addressing forbidden materials is correct. Based on the information you submitted, we agree that your client"s cleaning products may be offered for transportation and transported under the materials of trade exceptions in 49 CPR 173.6. To identify the material as being less hazardous than in a more concentrated form, you may want to consider including the concentration range of the active component in the common name or proper shipping name. Your unabridged letter and drawings are enclosed.
I hope this information is helpful. If you have additional questions, please do not hesitate to contact this office.
Sincerely,
Hattie L. Mitchell, Chief
Regulatory Review and Reinvention
Office of Hazardous Materials Standards
Enclosures
173.6
Regulation Sections
| Section | Subject |
|---|---|
| 173.6 | Materials of trade exceptions |