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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #14-0187 ([SHISEIDO Group USA] [Ms. Diana Olivari])

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

Interpretation Response Details

Response Publish Date:

Company Name: SHISEIDO Group USA

Individual Name: Ms. Diana Olivari

Location State: NJ Country: US

View the Interpretation Document

Response text:

Ms. Diana Olivari
Senior Manager Logistics
301 Rte 17

Rutherford, NJ 07070

Ref. No.: 14-0187

Dear Ms. Olivari:

This responds to your October 6, 2014 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to packagings permanently marked with a special permit number. In your letter, you note that you offer for transportation packagings that utilized "DOT-SP 9275." This special permit authorized the transportation in commerce of certain limited quantities of liquids and solids containing ethyl alcohol and exempted these shipments from the provisions of 49 CFR Parts 100-185. Further, you acknowledge that PHMSA incorporated the provisions of "DOT-SP 9275" into the HMR under the HM-233C Final Rule published in the Federal Register on March 18, 2014 [79 FR 15033], and effective April 17, 2014. Special permit "DOT-SP 9275" became unnecessary because this Final Rule added a new paragraph (g) to § 173.150 authorizing limited quantities of retail products containing ethyl alcohol. You ask whether you may continue to offer for transportation packagings that were pre-printed prior to the Final Rule’s effective date and permanently marked with "DOT-SP 9275" even though the special permit is no longer necessary?

The answer is yes. As provided in § 173.23(h), a packaging that is permanently marked with a special permit number, "DOT-SP" or "DOT-E," for which the provisions of the special permit have been incorporated into the HMR may continue to be used for the life of the packaging without obliterating or otherwise removing the special permit number.

I trust this satisfies your inquiry. Please contact us if we can be of further assistance.



T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division

173.150, 173.23(h)

Regulation Sections

Section Subject
173.150 Exceptions for Class 3 (flammable and combustible liquids)
173.23 Previously authorized packaging