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Interpretation Response #12-0115 ([Forrest Paint Company] [Mr. Rich Nolan])

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

Interpretation Response Details

Response Publish Date:

Company Name: Forrest Paint Company

Individual Name: Mr. Rich Nolan

Location State: OR Country: US

View the Interpretation Document

Response text:

June 21, 2012



Mr. Rich Nolan
Forrest Paint Company
1011 McKinley
Eugene, Oregon 97402

Ref. No. 12-0115

Dear Mr. Nolan:

This responds to your May 10, 2012 request for clarification on shipping limited quantities under the Hazardous Materials Regulations (HMR; 49 CFR 171-180). You ask for verification that you are properly describing and marking highway shipments of aerosols, paints, and alcohol based gel under the limited quantity provisions taking effect December 31, 2013. In addition, you ask if the "LTD QTY" designation may be used to describe the materials on a shipping paper.

The Hazardous Materials Table (HMT; § 172.101) provides packaging exceptions in Column 8A. Provided the aerosol paints, alcohol based gels, and flammable paints comply with the packaging exception specified in Column 8A of the HMT, and are transported by ground, your understanding is correct. The marking specified in § 172.315(a)(1) would be the appropriate marking.

In accordance with § 172.200(a)(3), a limited quantity package shipped by ground is not required to have a shipping paper. While not required, the HMR does not prohibit a limited quantity package shipped by ground from being included on a shipping paper. It should be noted that the practice of permissively including a hazardous material excepted from the shipping paper requirements on a shipping paper may lead to frustration of the shipment and is not recommended.

I hope this answers your inquiry. If you need additional assistance, please contact this office at (202) 366-8553.



Robert Benedict
Chief, Regulations Development Branch
Standards and Rulemaking Division

172.101, 172.315, 172.200

Regulation Sections

Section Subject
172.101 Purpose and use of hazardous materials table
172.200 Applicability
172.315 Limited quantities