Interpretation Response #09-0266 ([Argonne National Laboratory] [Mr. John Pearson])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Argonne National Laboratory
Individual Name: Mr. John Pearson
Location State: IL Country: US
View the Interpretation Document
Response text:
January 8 , 2010
Mr. John Pearson
Materials Science Division
Argonne National Laboratory
9700 South Cass Avenue
Argonne, IL 60439
Ref. No.: 09-0266
Dear Mr. Pearson:
This responds to your letter dated November 9, 2009 requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the small quantity exception. Specifically, you ask if the person who classes, ensures compliance, and offers a hazardous material into transportation using the small quantity exception is subject to formal training requirements under the HMR.
The answer is no. Materials that meet the requirements of 49 CFR § 173.4 are not subject to any other requirements of the HMR. Therefore, persons who ship hazardous materials under the provisions of § 173.4 are not subject to the formal training requirements of Subpart H in Part 172. A person who offers small quantity shipments under § 173.4 is still responsible for properly classifying and naming the material as well as correctly determining if the material may be shipped as a small quantity. Thus, persons who ship hazardous materials under the small quantity exception will find it necessary to acquire the basic knowledge necessary to understand the provisions in § 173.4 and the provisions applicable to classifying the hazardous material they intend to ship under the small quantity exception.
I hope this answers your inquiry.
Sincerely,
Charles E. Betts
Chief, Standards Development
Office of Hazardous Materials Standards
173.4
Regulation Sections
| Section | Subject |
|---|---|
| 173.4 | Small quantities for highway and rail |