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Interpretation Response #08-0187 ([Crown Holdings, Inc.] [Ms. Maria L. Evangelista])

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

Interpretation Response Details

Response Publish Date:

Company Name: Crown Holdings, Inc.

Individual Name: Ms. Maria L. Evangelista

Location State: IL Country: US

View the Interpretation Document

Response text:

February 11, 2009








Ms. Maria L. Evangelista

Crown Holdings, Inc.

11535 S. Central Ave.

Alsip, IL 60803

Ref. No. 08-0187

Dear Ms. Evangelista:

This is in response to your request asking for clarification regarding requirements for marking specification 2P and 2Q inner non-refillable aerosol receptacles. You state that the receptacles are manufactured in the United States, but are filled and distributed solely in Canada. You ask whether the specification receptacles may be marked in accordance with Transport Canada"s Transport of Dangerous Goods Regulations (TDG Regulations) or must they also conform to the specification marking requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).

Regardless of where the aerosol receptacles are manufactured, if they conform to the TDG Regulations, they may be marked as such and are not required to also be marked in accordance with the HMR.

For your information, § 171.12(a)(2) provides for the use and transport in the United States of hazardous materials in packagings authorized by the TDG Regulations, subject to certain limitations, including equivalency to DOT specification or UN packaging authorized under the HMR.

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

Sincerely,

Hattie L. Mitchell

Chief, Regulatory Review and Reinvention

Office of Hazardous Materials Standards

171.12(a)(2) 178.819

Regulation Sections

Section Subject
171.12 North American Shipments