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Interpretation Response #04-0189 ([Retrotec Inc.] [Mr. Carl Piehl])

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

Interpretation Response Details

Response Publish Date:

Company Name: Retrotec Inc.

Individual Name: Mr. Carl Piehl

Location State: WA Country: US

View the Interpretation Document

Response text:

Nov 9, 2004

 

Mr. Carl Piehl                 Reference No. 04-0189
Production Manager
Retrotec Inc.
2200 Queen St., #12
Bellingham, WA 98226

Dear Mr. Piehl:

This is in response to your letter dated August 12, 2004 requesting clarification of the small quantity exception found in § 173.4 of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if you can place 25 air current testers each containing 10 ml of”Titanium tetrachloride, UN1838, 8, (6.1), PG II” in a outer packaging and ship the completed package as a small quantity under § 173.4. Additionally, you state that you would like to ship your titanium tetrachloride by air under exemption DOT-B 6971.

“Titanium tetrachloride, UN1838, 8, (6.1), PG II” meets the definition of a Division 6.1, PG I, Zone B material. Therefore, you cannot place 25 air current testers each containing 10 ml of titanium tetrachloride in an outer packaging and ship the completed package under the small quantity exception found in § 173.4. In accordance with § 173.4(a)(1)(iii), the maximum quantity of “Titanium tetrachloride, TJN1 838, 8, (6.1), PG II per sinner receptacle or article is limited to 1g (0.04 ounces).

To request p arty status to exemption DOT-B 6971 you must submit your application to the Associate Administrator for Hazardous Materials Safety in accordance with § 107.107.

I hope this information is helpful. Please contact us if you require additional assistance.

Sincerely,

 

Edward T. Mazzullo
Director, Office of Hazardous
   Materials Standards

173.4

Regulation Sections