Interpretation Response #14-0149
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
December 23, 2014
Mr. Armando Sancerni
3060 NW 126th Ave.
Doral, FL 33323
Ref. No.: 14-0149
Dear Mr. Sancerni:
This is in response to your letter dated July 22, 2014 requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) regarding transportation requirements for UN2717 Camphor. You note that this particular commodity has no exceptions listed in column 8a of the § 172.101 Hazardous Materials Table, and that the International Civil Aviation Organization Technical Instructions (ICAO TI) allow both excepted and limited quantity shipments of this material as well as shipments offered as consumer commodities. You ask if you are authorized to use the ICAO TI and offer UN2717 as a limited quantity, excepted quantity, or consumer commodity.
Section 171.22(b) authorizes shipments made in conformance with various international standards, including the ICAO TI. A shipment of Camphor UN2717 may be offered as either a limited quantity or excepted quantity shipment for transportation or transported within the United States by aircraft and by motor vehicle or rail either before or after being transported by aircraft in accordance with the provisions of the ICAO TI as authorized by § 171.22(b). Camphor UN2717 is not authorized to be offered as a consumer commodity under the ICAO TI. We have noted this difference in domestic and international exceptions, and PHMSA may consider a regulatory approach to address the issue in the future.
I trust this information is helpful. If you have further questions, please do not hesitate to contact this office.
Shane C. Kelley
Acting International Standards Coordinator
Standards and Rulemaking Division
|§ 172.101||Purpose and use of hazardous materials table|