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Interpretation Response #05-0224 ([CMP Industries LLC] [Mr. William Regan])

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

Interpretation Response Details

Response Publish Date:

Company Name: CMP Industries LLC

Individual Name: Mr. William Regan

Location State: NY Country: US

View the Interpretation Document

Response text:

Oct 26, 2005


Mr. William Regan                    Reference No. 05-0224
President, CMP Industries LLC
413 No. Pearl Street
Albany, NY 12207

Dear Mr. Regan:

This is in response to your request for clarification of the requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) pertaining to hazardous materials authorized to be transported under the proper shipping name “Consumer commodity.” Specifically, you ask whether “Methyl methacrylate monomer, stabilized,” UN1247 and “Ethyl methacrylate, stabilized,” UN2277 may be transported as “Consumer commodity,” ORM-D.

The answer is yes, provided certain conditions are met. For the entries “Methyl methacrylate monomer, stabilized,” UN1247 and “Ethyl methacrylate, stabilized,” UN2277, § 173.150 is referenced in Column (8A) of the Hazardous Materials ‘fable (HMT). Section 173.150 authorizes UN1247 and UN2277 to be renamed “Consumer commodity” and reclassed as ORM-D provided the packages meet the limited quantities provisions in § 173.150(b) and are consumer commodities as defined in § 171.8 (see § 173.150(c)). Therefore, if the inner packages for your Packing Group II materials are not over 1.0 liter (0.3 gallon) net capacity each and are suitable for sale in retail outlets, your materials may be transported as “Consumer commodity,” ORM-D. As provided in § 173.150, the inner packages must be packed in a strong outer packaging not to exceed 30 kg (66 pounds) gross weight each, and each packaging must conform to the packaging requirements of Subpart B of Part 173.

In addition to the exceptions in § 173.150(b), ORM-D materials are not subject, to shipping paper requirements unless the material meets the definition of a hazardous substance, hazardous waste, marine pollutant, or is offered for transportation and
transported by aircraft. ORM-D materials are also eligible for the exceptions provided in § 173.156. Please note that the HMT contains a “D” in Column (1) for the “Consumer commodity” entry (see § 172.101(b)(3)).





I hope this information is helpful. Should you have additional questions, please do not hesitate to contact this office.



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

172.101, 172.150

Regulation Sections

Section Subject
172.101 Purpose and use of hazardous materials table