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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.



Susan Gorsky

Acting Chief, Standards Development

Office of Hazardous Materials Standards

173.301, 173.25

Regulation Sections

Section Subject
173.25 Authorized packagings and overpacks
173.301 General requirements for shipment of compressed gases and other hazardous materials in cylinders, UN pressure receptacles and spherical pressure vessels