Interpretation Response #06-0188 ([Hazardous Materials Training Compliance] [Mr. Philip C. Rieke])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Hazardous Materials Training Compliance
Individual Name: Mr. Philip C. Rieke
Location State: WA Country: US
View the Interpretation Document
Response text:
Sep 8, 2006
Administration
Mr. Philip C. Rieke Reference No. 06-0188
Hazardous Materials Training Compliance
7109 West Wernett Road
Pasco, WA 99301
Dear Mr. Rieke:
This is in response to your letter requesting clarification of the shipping paper and marking requirements under the Hazardous Materials Regulations (HMR; 49 CFR Part; 171-180) applicable to limited quantities of Class 7 (radioactive) materials. Specifically, you ask about the appropriate shipping description for limited quantity shipments for which shipping papers are required and package marking requirements for excepted packages.
Sections 173.421, 173.424, 173.426 and 173.428 contain requirements for transporting excepted quantities of Class 7 (radioactive) materials, including limited quantities. If you are preparing packages for shipment in accordance with these sections, you may take advantage of the additional exceptions in § 173.422. The introductory paragraph of
§ 173.422 excepts such packages from all other HMR requirements except for the requirements in § 173.422 and the applicable packaging section (such as § 173.421). Unless the package contains a Class 7 (radioactive) material that is also a hazardous substance or hazardous waste, no shipping paper is required. In accordance with
§ 172.203(b), for a limited quantity shipment that also is a hazardous substance or hazardous waste, when the words “limited quantity” are part of the proper shipping name, you need not repeat the words “limited quantity” following the basic description.
With respect to the identification number of the material being transported, you are correct that it’s marking on the package is not required to be placed within a square-on-point border for packages prepared for shipment as described in the above paragraph.
I hope this information is helpful. Please contact this office if you have additional questions.
Sincerely,
Hattie L. Mitchell
Chief, Regulatory Review and Reinvention
Office of Hazardous Materials Standards
173.422