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Interpretation Response #12-0152 ([Curran International] [Mr. Chris Gomez])

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

Interpretation Response Details

Response Publish Date:

Company Name: Curran International

Individual Name: Mr. Chris Gomez

Location State: TX Country: US

View the Interpretation Document

Response text:

January 2, 2013

Mr. Chris Gomez
Curran International
3610 Vicksburg Lane
Dickinson, Texas   77539

Ref. No. 12-0152

Dear Mr. Gomez:     

This responds to your July 10, 2012 letter requesting clarification of the packaging provisions for "UN 3066, Paint Related Material, 8, III" under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Specifically, you describe a shipment of "UN 3066, Paint Related Material, 8, III" composed of a hardener and a base and ask if these two packaging configurations comply with the HMR.

In your incoming letter, you describe the following two packaging configurations:

Packaging Configuration 1: The hardener comes in a one quarter kit, is locked with three lid locks, positioned inside a clear plastic bag, inserted in a Uline S-7449 box designed to contain one quart round openhead metal can with friction lids and armlok closures.  This box is then sealed with clear packing tape 3M tape. The base comes in a three quarter kit non-hazardous material, is inserted in a clear plastic bag.

Packaging Configuration 2: Two hardeners and two bases are placed in the 4 gallon fiber S-7372 box.  The void space is filled with bubble wrap, which is wrapped all around top and bottom of the hardener and the base edges.   The fiber box is then closed and sealed with a clear packing tape 3M tape.  The gross mass of the package does not exceed that originally tested. 

In accordance with § 173.173, "UN 3066, Paint Related Material, 8, III" may be packaged in authorized packages listed in § 173.203.  In addition, "UN 3066, Paint Related Material, 8, III" may be packaged in inner glass packaging of not over 1 L (0.3 gallons) capacity each or inner metal packaging of not over 5 L (1 gallon) each, packaged in a strong outer packaging.  These packages must conform to the packaging requirements of subpart B of this part but need not conform to the requirements of part 178 of this subchapter.      

A member of our staff has contacted you both by telephone and by email requesting clarification and additional information regarding your packaging configurations. We have not received a response to our request for clarification and additional information. Based on your letter and description of the packaging configurations, insufficient information has been provided, so we cannot formulate an opinion. Specifically, no drawings or diagrams have been submitted and the descriptions of your packaging configurations are unclear.     

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


Robert Benedict
Chief, Standards Development Branch
Standards and Rulemaking Division


Regulation Sections

Section Subject
173.173 Paint, paint-related material, adhesives, ink and resins.