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Interpretation Response #08-0002 ([Kajuligan Corporation] [Mr. Clifford E. Croft])

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

Interpretation Response Details

Response Publish Date:

Company Name: Kajuligan Corporation

Individual Name: Mr. Clifford E. Croft

Location State: IL Country: US

View the Interpretation Document

Response text:

February 21, 2008


Mr. Clifford E. Croft

Director, Regulatory Compliance

Kajuligan Corporation

316 Crescent Place

Geneva, IL 60134

Reference No. 08-0002

Dear Mr. Croft:

This responds to your letter, postmarked December 14, 2007, concerning requirements in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to small quantity shipments. Specifically, you ask about requirements applicable to packages prepared in accordance with § 173.4 and overpacked in a fiberboard box. Your questions are paraphrased and answered as follows:

Q1. If packages conforming to the requirements in § 173.4 are overpacked in a fiberboard box, must the overpack successfully pass the package testing requirements specified in § 173.4(a)(6)?

A1. No. The package testing requirements apply to the packaging configurations specified in § 173.4.

Q2. If packages conforming to the requirements in § 173.4 are overpacked in a fiberboard box, must the overpack be marked "This package conforms to 49 CFR 173.4"? If not, must the overpack be marked "OVERPACK"?

A2. The marking specified in § 173.4 is the shipper"s statement certifying that a package conforms to the requirements set forth in that section. No certification mark is required for the overpack. Further, packages prepared in accordance with § 173.4 are excepted from all other HMR requirements. Thus, the marking requirements in § 173.25 applicable to overpacks do not apply to overpacks containing packages prepared in accordance with § 173.4.

Q3. May the overpack exceed the 29 kg gross weight limit specified in § 173.4(a)(8)?

A3. Yes. The weight limitation applies to individual packages prepared in accordance with § 173.4.

I hope this satisfies you request.

Sincerely,

Hattie L. Mitchell, Chief

Regulatory Review and Reinvention

Office of Hazardous Materials Standards

173.4

Regulation Sections

Section Subject
173.4 Small quantities for highway and rail