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Interpretation Response #10-0184 ([Baker Petrolite Corporation] [Mr. Aubrey Campbell])

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

Interpretation Response Details

Response Publish Date:

Company Name: Baker Petrolite Corporation

Individual Name: Mr. Aubrey Campbell

Location State: TX Country: US

View the Interpretation Document

Response text:

October 21, 2010




Mr. Aubrey Campbell

Senior Transportation Specialist

Baker Petrolite Corporation

12645 West Airport Boulevard

Sugar Land, TX 77478

Ref. No.: 10-0184

Dear Mr. Campbell:

This responds to your August 31, 2010 request for clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). According to your letter and subsequent telephone conversation with a member of my staff, you transport coiled tubing containing residual amounts of a Class 3 material, in Packing Group III. You indicate that the tubing holds 10 gallons at the most, but the tubing and spool weigh over 1000 pounds. Specifically, you ask if the completed package would meet the requirements of § 173.6.

Based on the information provided, the gross weight and capacity of the completed package is above the limits for MOTs provided in § 173.6(a)(1)(ii) (66 pounds or 8 gallons). Therefore, you may not use the MOTs exception.

You may wish to pursue transporting the packaging configuration you describe under § 173.29.

I trust this satisfies your inquiry. Please contact us if we can be of further assistance.


Ben Supko

Acting Chief, Standards Development

Office of Hazardous Materials Standards

173.6, 173.29

Regulation Sections

Section Subject
173.29 Empty packagings
173.6 Materials of trade exceptions