Interpretation Response #11-0127 ([Veolia Environmental Services] [Ms. Jennifer Eberle])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Veolia Environmental Services
Individual Name: Ms. Jennifer Eberle
Location State: NJ Country: US
View the Interpretation Document
Response text:
September 8, 2011
Ms. Jennifer Eberle
Manager, Transportation Compliance
Veolia Environmental Services
1 Eden Lane
Flanders, NJ 07836
Reference No. 11-0127
Dear Ms. Eberle:
This is in response to your May 26, 2011 letter concerning the display of the "ORM-D" hazard class on a shipping paper for a "Consumer commodity." Specifically, you ask if it is permissible to omit the hyphen between the letters "m" and "d" under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).
The answer is no. Although the HMR permit a proper shipping name to appear on a shipping paper without punctuation marks (see § 172.101(c), it provides no such relief for the display of a hazard class.
For your information, please note that the HMR is phasing out use of the ORM-D hazard class and it will no longer be permitted to be used in domestic transportation after December 31, 2013 (see 76 FR 3308, 1/19/2011, Docket No. PHMSA-2009-0126 (HM-215K)). Various sections of the HMR will implement new limited quantity provisions in its place that will establish a standardized system for national and international multimodal transportation. Under this new system, consumer commodities will have the same provisions and requirements for international and national transportation as the approach for deminimis quantities, and excepted quantities, and will promote compliance, efficiency and consistent training and lower costs after implementation.
I hope this satisfies your request.
Sincerely,
T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division
172.101
Regulation Sections
| Section | Subject |
|---|---|
| 172.101 | Purpose and use of hazardous materials table |