Interpretation Response #10-0030 ([Environmental Scientist URS Corporation] [Ms. Erin N. Jarmin])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Environmental Scientist URS Corporation
Individual Name: Ms. Erin N. Jarmin
Location State: NC Country: US
View the Interpretation Document
Response text:
March 30, 2010
Ms. Erin N. Jarmin
Environmental Scientist
URS Corporation
1600 Perimeter Park Drive, Suite 400
Morrisville, NC 27560
Ref. No. 10-0030
Dear Ms. Jarman:
This responds to your February 3, 2010 letter concerning the exceptions for ORM-D materials under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). According to your letter, a distribution facility offers for transportation automotive parts, classed as ORM-D materials and unitized, to a contract carrier whose specialized service is the transport and delivery of automotive parts to car dealerships. You ask whether the distribution facility may take advantage of the exceptions for ORM-D materials provided in § 173.156(b)(1) if the materials are transported to multiple destinations as part of one shipment.
The answer is yes. In accordance with § 173.156(b)(1), ORM-D materials are excepted from the requirements of the HMR when: (1) unitized in cages, carts, boxes, or similar overpacks; (2) offered for transportation or transported by rail, private or contract motor carrier; or common carrier in a vehicle under exclusive use for such service; and (3) transported to or from a manufacturer, a distribution center, and a retail outlet, or transported to a disposal facility from one offeror. Thus, so long as the automotive parts (i.e., the ORM-D materials) remain unitized throughout the shipment to the car dealerships, the distribution facility offering the ORM-D materials to a contract carrier may use the exceptions provided in § 173.156(b)(1).
I hope this information is helpful. If you have further questions, please contact this office.
Sincerely,
Charles E. Betts
Chief, Standards Development
Office of Hazardous Materials Standards
173.156(b)(1)
Regulation Sections
| Section | Subject |
|---|---|
| 173.156 | Exceptions for limited quantity and ORM |