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Interpretation Response #15-0050 ([URS Corporation] [Mr. Andrew Romach])

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

Interpretation Response Details

Response Publish Date:

Company Name: URS Corporation

Individual Name: Mr. Andrew Romach

Location State: NC Country: US

View the Interpretation Document

Response text:

June 8, 2015

Mr. Andrew Romach
Regulatory Compliance Manager
URS Corporation
1600 Perimeter Park Dr.
Morrisville, NC 27560

Reference No. 15-0050

Dear Mr. Romach:

This is in response to your January 8, 2015 e-mail requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to use of the small quantities exception. Specifically, you ask whether a hazardous material with the word "None" in Column 8A of the § 172.101 Hazardous Materials Table (HMT) is eligible for the small quantities exception in § 173.4. You provide the example of "UN2734, Amines, liquid, corrosive, flammable, n.o.s., 8 (3), PGII."

Provided all the conditions specified in § 173.4 are met, the answer is yes. Section 172.101(i)(1) states: "Column 8A contains exceptions from some of the requirements of this subchapter. The referenced exceptions are in addition to those specified in subpart A of part 173 and elsewhere in this subchapter. A "None" in this column means no packaging exceptions are authorized, except as may be provided by special provisions in Column 7." Therefore, a "None" in column 8A of the § 172.101 HMT does not affect the eligibility for use of exceptions in Part 173 Subpart A, including the small quantities exception in § 173.4.

I hope this satisfies your request.


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

173.4, 172.101(i)(1), 172.101, 173.4

Regulation Sections

Section Subject
172.101 Purpose and use of hazardous materials table
173.4 Small quantities for highway and rail