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Interpretation Response #04-0128 ([Valspar] [Mr. Eric Barcaskey])

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

Interpretation Response Details

Response Publish Date:

Company Name: Valspar

Individual Name: Mr. Eric Barcaskey

Location State: MN Country: US

View the Interpretation Document

Response text:

Jun 24, 2004
Mr. Eric Barcaskey                 Reference No. 04-0128
Hazardous Materials Transport Compliance
1101 South Third Street
Minneapolis, MN 55415

Dear Mr. Barcaskey:

This responds to your June 1, 2004 letter requesting clarification on packaging requirements for consumer commodities under § 173.25(b) of the Hazardous Materials Regulations (HMR; stretch wrapped to a pallet as provided in your enclosed photograph meets the requirements of 173.25(b).

According to your letter, you ship aerosol cans that may contain materials that meet either Class 3 and or Division 6.1 under the HMR. You state that your products also meet the defining criteria in Part 173 for a limited quantity and consumer commodity under
§ 173.306(a)(3), 173.306(h) and 171.8. You ask if your proposed aerosol packaging meets the requirements of § 173.25(b). In addition, you ask if there is a weight limit for these packages stretch wrapped to a pallet.

It is the opinion of this Office that your proposed aerosol packaging does meet the
requirements of § 173.25(b). Section 173.25 (b) does not specify a weight limit for such packages stretch wrapped to a pallet.

I hope this answers your inquiry.



John A. Gale
Chief, Standards Development
Office of Hazardous Materials Standards


Regulation Sections

Section Subject
173.25 Authorized packagings and overpacks