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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

Section Subject
173.4 Small quantities for highway and rail