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Interpretation Response #10-0103 ([Calfrac Well Services Corp.] [Mr. Dave Mykyte])

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date:

Company Name: Calfrac Well Services Corp.

Individual Name: Mr. Dave Mykyte

Location State: AR Country: US

View the Interpretation Document

Response text:

May 26, 2010

 

 

 

 

Mr. Dave Mykyte

Calfrac Well Services Corp.

164 - Hwy 64

Beebe, Arkansas 72012



Ref. No. 10-0103

Dear Mr. Mykyte:

This responds to your April 28, 2010 email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You provide a description and pictures of a Class 7 (radioactive) material in a Type A package, which you refer to as a blender densitometer. The Type A package is attached to the frame of a machine mounted on a trailer. A steel sleeve that fits over the package is bolted in place using existing bolt holes on the frame of the Type A package to provide additional shielding. Specifically, you ask if the steel sleeve meets the definition of an overpack in the HMR.

The answer is no. An overpack is defined in § 171.8 to mean an enclosure used by a single consignor to provide protection or convenience in the handling of a package or to consolidate two or more packages. An example of an overpack is one or more packages placed in a protective outer packaging such as a box or crate. The steel sleeve semi-permanently attached to the Type A package is considered an attachment to the Type A package; therefore, it does not meet the definition of an overpack.

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

171.8

Regulation Sections

Section Subject
171.8 Definitions and abbreviations