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Interpretation Response #04-0219 ([MOL America, Inc] [Ms. Fumie Sloan])

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

Interpretation Response Details

Response Publish Date:

Company Name: MOL America, Inc

Individual Name: Ms. Fumie Sloan

Location State: CA Country: US

View the Interpretation Document

Response text:

Oct 26, 2004

 

Ms. Fumie Sloan                 Reference No. 04-0219
Senior Supervisor
MOL America, Inc.
One Concord Center
2300 Clayton Road, Suite #1500
Concord, CA 94520

Dear Ms. Sloan:

This is in response to your September 17, 2004 letter and discussion with Mr. Emmanuel Pfersich of the US Coast Guard requesting clarification of container/vehicle packing certificate requirements as specified under the International Maritime Dangerous Goods (IMDG) Code. Section 5.4.2.1 of the IMDG Code specifies that a “container/vehicle packing certificate is not required for tanks.” Specifically, you ask if a signed container/vehicle packing certificate may accompany a tank shipment of hazardous material.

In the opinion of this office, the presence of a signed container/vehicle packing certificate with a tank shipment of hazardous material does not appear to be in violation of 5.4.2.1 of the IMDG Code. In addition, we agree with Mr. Pfersich that failure to take advantage of this special condition for tanks may cause confusion among parties involved with the shipment, including competent authorities, and, as a result, could complicate or delay the shipment.

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

Sincerely,

 

Hattie Mitchell
Chief, Regulatory Review and Reinvention
Office of Hazardous Materials Standards

171.12, 176.27

Regulation Sections

Section Subject
171.12 North American Shipments
176.27 Certificate