Interpretation Response #08-0221 ([URS Corporation] [Ms. Erin N. Jarman])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: URS Corporation
Individual Name: Ms. Erin N. Jarman
Location State: NC Country: US
View the Interpretation Document
Response text:
September 29, 2008
Ms. Erin N. Jarman
Environmental Scientist
URS Corporation
1600 Perimeter Park Drive
Morrisville, NC 27560
Ref. No. 08-0221
Dear Ms. Jarman:
This responds to your September 2, 2008 letter requesting clarification of the overpack requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Your questions are paraphrased and answered below.
Q1. Does the strong non-bulk outer packaging required by § 173.301(a)(9) for specification 2P, 2Q, 3E, 3HT, spherical 4BA, 4D, 4DA, 4DS, and 39 cylinders constitute an overpack?
A. No. In this case, the specification cylinder is the inner packaging of a combination package. As specified in § 173.301(a)(9), the strong outer package must be marked with an indication that inner packages conform to the prescribed specifications. A shipper may not use the OVERPACK marking prescribed in § 173.25 to satisfy this requirement because this configuration does not constitute an overpack.
Q2. Does a box or crate used to protect cylinder valves in accordance with § 173.301(h) constitute an overpack? Is this package subject to the requirements of § 173.25 including the requirement to mark the word OVERPACK on the box or crate?
A2. Yes. An overpack means an enclosure that is used by a single consignor to provide protection or convenience in handling of a package or to consolidate two or more packages. In this case, the specification cylinder constitutes a single package and the box or crate provides additional protection. The box or crate must comply with § 173.25 including the
requirement to mark the word OVERPACK on the protective outer packaging when specification packages are used.
I hope this satisfies your inquiry. If we can be of further assistance, please contact us.
Sincerely,
Susan Gorsky
Acting Chief, Standards Development
Office of Hazardous Materials Standards
173.301, 173.25