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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.



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


Regulation Sections

Section Subject
173.156 Exceptions for limited quantity and ORM