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Interpretation Response #04-0144 ([Hammond, Group, Inc.] [Mr. James Bandstra])

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

Interpretation Response Details

Response Publish Date:

Company Name: Hammond, Group, Inc.

Individual Name: Mr. James Bandstra

Location State: IN Country: US

View the Interpretation Document

Response text:

Jul 13, 2004


Mr. James Bandstra                 Reference No. 04-0144
Environmental Manager
Hammond, Group, Inc.
1414 Field Street
Hammond, IN 46325-6408

Dear Mr. Bandstra:

This is in response to your May 5, 2004 letter regarding classification of certain lead compounds destined for export transportation under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask whether your company is allowed to classify your product as “Lead compounds, soluble, n.o.s., Division 6.1” for export transportation when it is known by testing not to meet the Division 6.1 criteria for poisonous materials. You state the material is a soluble lead compound and contains a reportable quantity of lead metal.

The shipping name “Lead compounds, soluble, n.o.s.” may not be used for a material that does not meet the criteria for a Division 6.1 material as specified in § 173.132 of the HMR. If you wish to apply for an exemption, the application for exemption procedures is found in § 107.105 of the HMR, or you may contact the Office of Hazardous Materials Exemptions and Approvals at 202-366-4511.

I hope this information is helpful.



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


Regulation Sections

Section Subject
172.101 Purpose and use of hazardous materials table