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Interpretation Response #07-0085 ([J.J. Keller & Associates, Inc.] [Mr. Thomas J. Ziebell ])

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

Interpretation Response Details

Response Publish Date:

Company Name: J.J. Keller & Associates, Inc.

Individual Name: Mr. Thomas J. Ziebell 

Location State: WI Country: US

View the Interpretation Document

Response text:

May 31, 2007

 

Mr. Thomas J. Ziebell                 Reference No. 07-0085
J.J. Keller & Associates, Inc.
3003 W. Breezewood Lane
Neenah, WI 54957-0368

Dear Mr. Ziebell:

This is in response to your April 13, 2007 letter requesting clarification of the changes to the specifications for the ORGANIC PEROXIDE (Division 5.2) label adopted under HM-2 151 (71 FR 78596; December 29, 2006). Specifically, you inquire about the transitional period for display of the Divisions 5.2 label conforming to specifications in effect on December 31, 2006 for transportation by highway.

Under HM-215I (71 FR 78596; December 29, 2006), PHMSA revised the specifications for ORGANIC PEROXIDE (Division 5.2) labels and placards for consistency with specifications in the UN Recommendations on the Transportation of Dangerous Goods. We added a transitional provision (§ 171.14(f)) to allow continued display of Division 5.2 labels and placards conforming to specifications in effect on December 31, 2006 until January 1, 2011. However, as discussed on page 78604 of HM-215I, we authorized an extended transitional period for display of Division 5.2 placards until January 1, 2014 for transportation by highway. We apologize for any confusion arising from the preamble discussion of § 171.14(f) indicating otherwise. The extended transitional period until January 1, 2014 does not apply to display of Division 5.2 labels for transportation by highway. For transportation by highway, Division 5.2 labels conforming to specifications in § 172.427 in effect on December 31, 2006 may be used until January 1, 2011 and Division 5,2 placards conforming to specifications in § 172.552 in effect on December 31, 2006 may be used until January 1, 2014.

I hope this information is helpful. Please contact us if you require additional assistance.

Sincerely,

 

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

171.14 (f), 172.427

Regulation Sections

Section Subject
172.427 ORGANIC PEROXIDE label