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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 #19-0015

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

Interpretation Response Details

Response Publish Date:

Company Name: Bombardier Aerospace

Individual Name: Jeff Christafore

Location State: WV Country: US

View the Interpretation Document

Response text:

August 8, 2019

Jeff Christafore
Dangerous Goods Compliance Specialist
Bombardier Aerospace
2400 Aviation Way
Bridgeport, WV 26330

Reference No. 19-0015

Dear Mr. Christafore:

This letter is in response to your February 7, 2019, email and subsequent phone conversations requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the transportation of packages covered under DOT-SP 15146. Specifically, you ask for clarification of party status requirements and the reoffering of packages shipped under DOT-SP 15146.

We have paraphrased and answered your questions as follows:

Q1. You ask whether a shipper must be granted party status to reoffer DOT-SP 15146 packages that have been opened and repacked.

A1. The answer is yes. Section 8(a) of DOT-SP 15146 stipulates that a person who is not a holder of the special permit may reoffer the package for transportation provided no modification or change is made to the package. It is the opinion of this Office that in this example modifying the "package," as defined in § 171.8, includes opening and/or repacking the package.

Q2. You ask whether "package" as referenced in section 8(a) means the inner aerosol container or the "packaging plus its contents," as defined in § 171.8.

A2. Section 8(a) refers to the "package" as defined in § 171.8. The HMR define package as "a packaging plus its contents." Therefore, in section 8(a) of DOT-SP 15146, the "package" refers to the strong outer packaging plus the inner aerosol containers.

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


Regulation Sections

Section Subject
171.8 Definitions and abbreviations