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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.


Charles E. Betts

Chief, Standards Development

Office of Hazardous Materials Standards


Regulation Sections

Section Subject
173.156 Exceptions for limited quantity and ORM