Interpretation Response #05-0315 ([Global Logistics Services] [Ms. Joan M. Boardman])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Global Logistics Services
Individual Name: Ms. Joan M. Boardman
Location State: TN Country: US
View the Interpretation Document
Response text:
Feb 3, 2006
Ms. Joan M. Boardman Reference No. 05-0315
Global Logistics Services
Pfizer, Inc.
1855 Shelby Oaks Drive North
Memphis, TN 38 134-7401
Dear Ms. Boardman:
This responds to your December 8, 2005 letter requesting clarification on marking requirements for your ORM-D material under the Hazardous Materials Regulations (HMR: 49 CFR Parts 171-180). According to your letter, you ship your ORM-D materials in “club pallets” consisting of two bottles in a strong fiberboard tray. Trays are then palletized and shrink-wrapped as one and transported to the consignee.
In accordance with § 173.156, packages of materials described as “Consumer commodity, ORM-D” are not subject to the marking requirements prescribed in Subpart D of Part 172, including § 172.3 16, when unitized in cages, carts, boxes or similar overpacks, and when offered for transportation or transported by a private or contract motor carrier or a common carrier vehicle under exclusive use for such service, from a manufacturer to a distribution center, from a manufacturer or distribution center to a retail outlet, or return.
I hope this answers your inquiry.
Sincerely,
John A. Gale
Chief, Standards Development
Office of Hazardous Materials Standards
173.156
Regulation Sections
| Section | Subject |
|---|---|
| 173.156 | Exceptions for limited quantity and ORM |