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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.



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