Interpretation Response #12-0223 ([Mr. John A Desharnais])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name:
Individual Name: Mr. John A Desharnais
Location State: MA Country: US
View the Interpretation Document
Response text:
October 19, 2012
Mr. John A Desharnais
103 South St.
Tewksbury, MA 01876
Ref No.: 12-0223
Dear Mr. Desharnais:
This is a response to your August 25, 2012 letter regarding the applicability of the Hazardous Materials Regulations (HMR; 49 CFR Parts 100-185) to "Carbon dioxide, solid or Dry ice, class 9, UN1845" when transported by highway. Specifically, you note the symbols "A" and "W" in column 1 of the Hazardous Materials table (HMT; § 172.101) for "Carbon dioxide, solid or Dry ice, class 9, UN1845" and ask if dry ice must comply with the shipping paper requirements specified in § 172.202 when transported by highway.
The answer to your question is no. As described in §§ 172.101(b)(2) and (b)(6) an "A" symbol in column 1 of the HMT denotes a material that is subject to the requirements of this subchapter only when offered or intended for transportation by aircraft, unless the material is a hazardous substance or a hazardous waste while a "W" symbol in column 1 of the HMT denotes a material that is subject to the requirements of this subchapter only when offered or intended for transportation by vessel, unless the material is a hazardous substance or a hazardous waste. Therefore, unless the "Carbon dioxide, solid or Dry ice, class 9, UN1845" is a hazardous substance or hazardous waste it is not subject to the HMR when transported by highway.
I hope this information is helpful. If you have any more questions, please do not hesitate to contact this office.
Sincerely,
Robert Benedict
Chief, Standards Development
Standards and Rulemaking Division
172.101
Regulation Sections
| Section | Subject |
|---|---|
| 172.101 | Purpose and use of hazardous materials table |