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Interpretation Response #13-0113 ([Alden Leeds, Inc.] [Mr. Mark Viscont])

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

Interpretation Response Details

Response Publish Date:

Company Name: Alden Leeds, Inc.

Individual Name: Mr. Mark Viscont

Location State: NJ Country: US

View the Interpretation Document

Response text:

June 19, 2013


Mr. Mark Visconti
Alden Leeds, Inc.
55 Jacobus Avenue
South Kearny, NJ   07032

Ref. No. 13-0113

Dear Mr. Visconti:

This responds to your May 15, 2013 request for clarification on how to describe and transport swimming pool chlorinating tablets under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you describe a package configuration and ask if the package complies with the consumer commodity requirements specified in § 173.152(c).

In your letter, you indicate that you are shipping swimming pool chlorinating tablets classified as UN2468, Trichloroisocyanuric acid, dry, 5.1, PGII.  These tablets are placed in a plastic pail outer package weighing 40 pounds.  The tablets are each sealed in clear plastic wrapping as an inner packaging and placed in the outer packaging.  Each plastic wrapped inner packaging is 8 ounces.   Based on this packaging configuration, you ask the following:

Q1.  What is DOT’s definition of an inner packaging?

A1.   As defined in § 171.8, an inner packaging is a packaging for which an outer packaging is required for transport.  It does not include the inner receptacle of a composite packaging.

Q2.  Do the tablets in the enclosed photos meet the requirement for an inner packaging?

A2.   Yes, according to your enclosed photos, the tablets, as contained in sealed plastic inner packaging meet the definition of an inner packaging as defined in § 171.8.

Q3.   Does this material and packaging configuration meet the consumer commodity requirement specified in 173.152(c)?

A3.   Yes, provided the material meets the definition of consumer commodity specified in § 171.8, each package conforms to the packaging requirements of subpart B of part 173, the overall package does not exceed 30 kg (66 pounds), and, for packing group II solids, the inner packagings do not exceed 1.0 kg (2.2 pounds) net capacity.

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


Robert Benedict
Chief, Standards Development Branch
Standards and Rulemaking Division

173.152, 171.8

Regulation Sections

Section Subject
171.8 Definitions and abbreviations
173.152 Exceptions for Division 5.1 (oxidizers) and Division 5.2 (organic peroxides)