Interpretation Response #06-0090 ([Target Specialty Products] [Mr. Gary Maxwell])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Target Specialty Products
Individual Name: Mr. Gary Maxwell
Location State: CA Country: US
View the Interpretation Document
Response text:
Jun 15, 2006
Mr. Gary Maxwell Reference No. 06-0090
Target Specialty Products
15415 Marquardt Avenue
Santa Fe Springs, CA 90670-5711
Dear Mr. Maxwell:
This is in response to your April 13, 2006 letter regarding the Materials of Trade exception under § 173.6 of the Hazardous Materials Regulations (HMR; 49 CFR Parts
171-180). Specifically, you ask if a hazardous material transported under the Materials of Trade exception may be transported (when originally packaged in combination packaging) without the strong outer packaging provided by the manufacturer.
The answer is yes. Under § 173.6(b)(3) outer packagings are not required for receptacles (e.g., cans and bottles) that are secured against shifting in cages, carts, bins, boxes or compartments. A cylinder or other pressure vessel (e.g., an aerosol can) containing a Division 2.1 or 2.2 material must conform to packaging, qualification, maintenance, and use requirements of this subchapter, except that outer packagings are not required. Packaging for materials of trade must be the manufacturer’s original packaging a packaging of equal or greater strength and integrity.
I hope this information is helpful. If you have further questions, please do not hesitate to contact this office.
Sincerely,
Hattie L. Mitchell
Chief, Regulatory Review and Reinvention
Office of Hazardous Materials Standards
171.8, 173.6 (b)(3)
Regulation Sections
| Section | Subject |
|---|---|
| 171.8 | Definitions and abbreviations |
| 173.6 | Materials of trade exceptions |