Interpretation Response #23-0086

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

Interpretation Response Details

Response Publish Date: 05/01/2024

Company Name: Azelis

Individual Name: Ms. Cindy Murphy

Location State: CT Country: US

View the Interpretation Document

Response text:

May 1, 2024

Ms. Cindy Murphy
National Logistics Manager
Azelis
33 Riverside Avenue, 5th Floor
Westport, CT  06880-4223

Reference No. 23-0086

Dear Ms. Murphy:

This letter is in response to your September 19, 2023, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to marking requirements when shipping marine pollutants by highway in non-bulk packagings. In your email, you describe a scenario where non-bulk packagings (i.e., drums) containing a marine pollutant have been marked with the United Nations (UN) number, proper shipping name, hazard class, and packing group—e.g., "UN3082, Environmentally hazardous substance, liquid, n.o.s. (contains Octocrylene), 9, PGIII." Specifically, you ask whether you may cover these markings when offering these packagings for transportation domestically by highway, as well as whether hazardous materials shipping information must be included on any shipping papers if you do not cover the markings.

Provided the material is only a marine pollutant and does not meet any other hazard class under the HMR, the markings may be covered if you choose to do so. In accordance with § 171.4(c), the requirements of the HMR, including to those pertaining to package markings and shipping papers—specific to marine pollutants—do not apply to non-bulk packagings transported by motor vehicle, rail car, or aircraft.

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

Sincerely,

Steven Andrews
Acting Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division

171.4(c)

Regulation Sections