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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 #18-0056

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

Interpretation Response Details

Response Publish Date:

Company Name: Outsource Logistics, LLC

Individual Name:

Location State: GA Country: US

View the Interpretation Document

Response text:

September 13, 2018

James Harnage
Safety and Regulatory Compliance Manager
Outsource Logistics, LLC
P.O. Box 2290
Valdosta, GA  31604

Reference No. 18-0056

Dear Mr. Harnage:

This letter is in response to your April 10, 2018, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to shipping paper requirements. You state that Outsource Logistics, LLC transports containers of a product called Manzate Pro Stick domestically. The product is initially shipped to the United States by vessel as a Class 9 marine pollutant in accordance with the International Maritime Dangerous Goods (IMDG) Code. You further state that Manzate Pro Stick contains two different active components: Mancozeb and Ethylenethiourea. It is your understanding that based on the active components in Manzate Pro Stick and because of the weight (in lbs) of one of the product components, Manzate Pro Stick would meet the requirements of a limited quantity and therefore be excepted from shipping paper requirements found in § 173.155(b). In addition, this Office obtained a Safety Data Sheet and test data from United Phosphorus Inc. (UPI) that describe Manzate Pro Stick as "UN3077, Environmentally hazardous substance, solid, n.o.s. (Mancozeb), 9, PG III," for transportation purposes.

According to § 171.4(c)(1), except when all or part of the transportation is by vessel, the requirements of the HMR specific to marine pollutants do not apply to non-bulk packagings transported by motor vehicle, rail, or aircraft. Furthermore, in accordance with § 171.4(c)(2), single or combination packagings having a net mass per single or inner packaging of 5 kg (11 lbs) or less for solids are not subject to any other requirements of the HMR, provided the packagings meet the general requirements in §§ 173.24 and 173.24a and the marine pollutant is not a hazardous waste or a hazardous substance.

Since the product arrives in the United States by vessel and assuming the final destination is the port of entry (based on the originating shipping paper), this portion of the transportation has ended. Therefore, any further domestic transportation does not require a shipping paper for transportation by highway to Outsource Logistics, LLC's warehouse or to their customers, nor would it be subject to any other HMR requirements in accordance with § 171.4.

I hope this information is helpful. Please contact us if we can be of further assistance.


Dirk Der Kinderen
Chief, Standards Development Branch
Standards and Rulemaking Division

173.155(b), 171.4(c)(1), 171.4(c)(2), 173.24, 173.24a, 171.4

Regulation Sections

Section Subject
171.4 Marine pollutants
171.4 Marine pollutants
173.155 Exceptions for Class 9 (miscellaneous hazardous materials)
173.24 General requirements for packagings and packages