Interpretation Response #09-0205 ([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:
October 7, 2009
Ms. Erin N. Jarman
Environmental Scientist
URS Corporation
1600 Perimeter Park Drive
Morrisville, NC 27560
Ref. No. 09-0205
Dear Ms. Jarman:
This responds to your August 19, 2009 letter requesting clarification on the requirements for Consumer Commodity, ORM-D materials shipped by air under § 173.150(b) of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if Consumer Commodity, ORM-D materials are subject to the requirement to use absorbent material in §173.27(e).
The answer is yes. The requirements in § 173.27 apply to limited quantity shipments transported by aircraft. Because a shipment must conform to the applicable limited quantity provisions to qualify for the consumer commodity exceptions, the requirement to use absorbent material in § 173.27(e) also applies to consumer commodity shipments transported by aircraft.
I hope this answers your inquiry.
Sincerely,
Charles E. Betts
Chief, Standards Development
Office of Hazardous Materials Standards
173.27, 173.150