Interpretation Response #15-0180
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
December 8, 2015
Patricia M. Sobel
COSMO International Corporation
601 Fairway Drive
Deerfield Beach, FL 33441
Ref. No. 15-0180
Dear Ms. Sobel:
This responds to your letter of August 8, 2015 and subsequent telephone conversation with a member of my staff requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) and the International Maritime Dangerous Goods (IMDG) Code applicable to United Nations (UN) identification number (ID) markings for export shipments. With your request, you provided a shipping paper that indicates the shipment contained a variety of material identified as "UN3082, Environmentally hazardous substance, liquid, n.o.s.," as well as a material identified as "UN1760, Corrosive liquid, n.o.s." You state these materials were offered in non-bulk packaging not meeting any of the conditions listed in 184.108.40.206.1 of the IMDG Code that would require marking of the UN ID numbers on cargo transport units. Specifically, you ask for confirmation of your understanding that the display of UN ID numbers is not required on your dangerous goods containers per the requirements of the IMDG Code.
Based on the shipping paper and scenario you have provided, it is the opinion of this Office that your understanding is correct. In accordance with 220.127.116.11.1 of the IMDG Code, your dangerous goods container, as described, would not be required to display UN ID numbers. Provided all or part of the movement is by vessel, hazardous materials may be offered for transportation or transported to, from, or within the U.S. in accordance with the requirements of the IMDG Code and all applicable requirements of Part 171, Subpart C. See §§ 171.22, 171.23, and 171.25.
I hope this answers your inquiry. If you need additional assistance, please contact this Office again.
Dirk Der Kinderen
Acting Chief, Standards Development Branch
Standards and Rulemaking Division
171.22, 171.23, 171.25
|§ 171.25||Additional requirements for the use of the IMDG Code|