Interpretation Response #12-0018 ([United Parcel Service (UPS)] [Mr. Bob Cogen])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: United Parcel Service (UPS)
Individual Name: Mr. Bob Cogen
Location State: KY Country: US
View the Interpretation Document
Response text:
March 30, 2012
Mr. Bob Cogen
ADG Compliance Manager
United Parcel Service
9406 Grade Lane
Louisville, KY 40213
Ref. No. 12-0018
Dear Mr. Cogen:
This responds to your January 18, 2012 letter regarding limited quantity exceptions provided in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-185). On January 19, 2011, PHMSA published a final rule (HM-215K; 76 FR 3308) to align the HMR with international standards for the transportation of hazardous materials. Specifically, you request clarification on the applicability of outer package quantity limitations for air limited quantity packages adopted in the final rule. Your questions are paraphrased and answered as follows:
Q1. Are air limited quantity packages marked in accordance with § 172.315(d) subject to the outer package net quantity limits contained in 49 CFR 173.27 Table 3?
A1. Yes.
Q2. What, if any, transitional exceptions are allowed for the air transport of limited quantity packages that exceed the outer package net quantity limits contained in 49 CFR 173.27 Table 3?
A2. There are no transitional exceptions allowed for the air transport of limited quantity packages that exceed the outer package net quantity limits contained in 49 CFR 173.27 Table 3.
I hope this answers your inquiry. If you need additional assistance, please contact this office at (202) 366-8553.
Sincerely,
Ben Supko
Acting Chief, Standards Development Branch
Standards and Rulemaking Division
173.315, 173.27