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Interpretation Response #16-0005 ([CMA CGM (America), LLC.] [Mr. Chris Godfrey])

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

Interpretation Response Details

Response Publish Date:

Company Name: CMA CGM (America), LLC.

Individual Name: Mr. Chris Godfrey

Location State: VA Country: US

View the Interpretation Document

Response text:

June 03, 2016

Chris Godfrey
CMA CGM (America), LLC
5701 Lake Wright Drive
Norfolk, VA 23502

Ref. No. 16-0005

Dear Mr. Godfrey:

This responds to your letter of January 5, 2016 requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) and the International Maritime Dangerous Goods (IMDG) Code applicable to consignments of fish meal transported by vessel.  Specifically, you ask whether a laboratory analysis certificate is considered a certificate issued by a “recognized authority” in accordance with Special Provision 928 of the IMDG Code (“SP 928”).

SP 928 states, “The provisions of this Code shall not apply to…consignments of fish meal which are accompanied by a certificate issued by a recognized competent authority of the country of shipment or other recognized authority stating that the product has no self-heating properties in packaged form” [emphasis added].  Based on this Office’s understanding of the IMDG Code provision, it does not require an approval from the competent authority to ship fish meal as not regulated.  Further, it is our opinion that a laboratory analysis certificate is sufficient to be considered a certificate issued by a “recognized authority.”  Therefore, in accordance with SP 928, a consignment of fish meal transported by vessel would not be subject to the provisions of the IMDG Code if accompanied by a laboratory analysis certificate specifying that the shipment has no self-heating properties in packaged form.

Please note that, under § 173.22 of the HMR, it is the shipper’s responsibility to properly class and describe a hazardous material.  In addition, 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
Chief, Standards Development Branch
Standards and Rulemaking Division

173.22, 171.22, 171.23, 171.25, 171

Regulation Sections

Section Subject
171.22 Authorization and conditions for the use of international standards and regulations
171.23 Requirements for specific materials and packagings transported under the ICAO Technical Instructions, IMDG Code, Transport Canada TDG Regulations, or the IAEA Regulations
171.25 Additional requirements for the use of the IMDG Code
173.22 Shipper's responsibility