Interpretation Response #08-0177 ([Charkit Chemical Corporation] [Mr. Steve Catania])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Charkit Chemical Corporation
Individual Name: Mr. Steve Catania
Location State: CT Country: US
View the Interpretation Document
Response text:
September 8, 2008
Mr. Steve Catania
Charkit Chemical Corporation
32 Haviland Street
South Norwalk, CT 06854
Ref. No.: 08-0177
Dear Mr. Catania:
This is in response to your letter requesting requirements applicable to the transportation of non-hazardous materials. You state that you understand that the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) do not apply to non-hazardous materials, but are concerned whether there are requirements applicable to the transportation of non-hazardous materials. Specifically, you state that one of your customers asked whether it is acceptable to transport by ground a non-hazardous product without the product name and Chemical Abstract Service (CAS) number.
As you state, the HMR apply to the transportation of hazardous materials in commerce. You did not identify the material that is being transported. However, provided your customer"s product does not meet the hazard class defining criteria in Part 173 of the HMR, and is not a hazardous waste, hazardous substance, or marine pollutant, it is not subject to the HMR and is not subject to labeling requirements for purposes of transportation.
If the product does not meet the criteria for a hazardous material under the HMR, you may wish to contact the U.S. Consumer Product Safety Commission (CPSACPSC) and the Occupational Safety and Health Administration (OSHA), Department of Labor (http://www.cpsc.gov/ and http://www.osha.gov/ ). CPSA CPSC is charged with protecting the public from risks of certain consumer products and issues regulations for certain (primarily household) chemicals that may specify labeling requirements. OSHA is responsible for ensuring employee safety and health in the workplace and also issues regulations for certain chemicals that may specify labeling requirements.
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
171.1