Interpretation Response #10-0237 ([Avon Products Inc.] [Mr. Kevin Gannon])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Avon Products Inc.
Individual Name: Mr. Kevin Gannon
Location State: NY Country: US
View the Interpretation Document
Response text:
December 21, 2010
Mr. Kevin Gannon
Manager, Hazmat Compliance & Transportation
Avon Products Inc.
1 Avon Place
Rye, NY 10580
Ref. No.: 10-0237
Dear Mr. Gannon:
This is in response to your October 22, 2010, letter requesting clarification of requirements in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to consumer commodities shipped by air. Specifically, you ask if an air carrier has the discretion to require a package to display consumer commodity markings in accordance with the International Civil Aviation Organization's Technical Instructions for the Safe Transport of Dangerous Goods by Air (ICAO Technical Instructions) in lieu of markings required by the HMR.
A material shipped by air and described with the proper shipping name "Consumer commodity" may be offered and transported in accordance with the ICAO Technical Instructions as specified in § 171.24. The ICAO Technical Instructions describe consumer commodities as Class 9 while the HMR use the hazard class ORM-D. Since the HMR provide the option for shippers and carriers to use the ICAO Technical Instructions in domestic air commerce, airline carriers may require shippers to offer hazardous material for transport in accordance with the ICAO Technical Instructions.
I hope this answers your inquiry. If you need additional assistance, please contact the Standards and Rulemaking Division.
Sincerely,
Ben Supko
Acting Chief, Standards Development Branch
Standards and Rulemaking Division
171.24
Regulation Sections
| Section | Subject |
|---|---|
| 171.24 | Additional requirements for the use of the ICAO Technical Instructions |