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Interpretation Response #05-0183


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

Interpretation Response Details

Response Publish Date: 08-23-2005
Company Name: ShipMate, Inc.    Individual Name: Mr. Steven Charles
Location state: CA    Country: US

View the Interpretation Document


Response text:

Aug 23, 2005

 

Mr. Steven Charles Hunt                    Reference No. 05-0183
ShipMate, Inc.
18436 Hawthorne Blvd, Suite 201
Torrance, CA 90504

Dear Mr. Hunt: 

This responds to your July 30, 2005 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if a shipper may dual mark a package with both the limited quantity marking and. the ORM-D marking, and if so, whether shipping papers are required for surface transportation of that material.

The answer to your question is yes. A package may have multiple markings. A material that is packaged as a limited quantity and is properly classed as ORM-D may display both the ORM-D marking in § 172.316 and the limited quantity marking in § 172.315. Shipping papers are not required domestically for an ORM-D material, except when the material is offered or intended for transportation by air (§ 172.200(b)(3)).

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

Sincerely,

 

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

172.315, 172.316


Regulation Sections

Section Subject
§ 172.316 Packagings containing materials classed as ORM-D