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Interpretation Response #06-0256 ([REGSCAN, Inc.] [Mr. Russ Shanahan])

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

Interpretation Response Details

Response Publish Date:

Company Name: REGSCAN, Inc.

Individual Name: Mr. Russ Shanahan

Location State: PA Country: US

View the Interpretation Document

Response text:

Nov 27, 2006


Mr. Russ Shanahan                 Reference No. 06-0256
800 West Fourth Street
Williamsport, Pennsylvania 17701

Dear Mr. Shanahan:

This is in response to your November 1, 2006 letter requesting clarification under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) concerning the entry “Polyester resin kit,” UN3269. Specifically, you ask whether the packing group must be included as part of the shipping description.

The packing group as designated for a hazardous material in Column 5 of the § 172.101 Table must be included in the shipping description for the hazardous material. Generally, entries that are not assigned a packing group are excepted from the requirement (see
§ 172.202(a)(4)).

In accordance with Special Provision 40 of § 172.102, a polyester resin kit consists of a base material (Class 3, Packing Group II or III) and an activator (organic peroxide). The packing group for a polyester resin kit is determined using the criteria for Class 3, applied to the base material, and will be either Packing II or III. The packing group designation must be included as part of the shipping description on the shipping paper.

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



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

172.102, 172.202

Regulation Sections

Section Subject
172.102 Special provisions
172.202 Description of hazardous material on shipping papers