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Interpretation Response #98-0510 ([HMT Associates, L.L.C.] [Mr. Gordon Rousseau])

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

Interpretation Response Details

Response Publish Date:

Company Name: HMT Associates, L.L.C.

Individual Name: Mr. Gordon Rousseau

Location State: DC Country: US

View the Interpretation Document

Response text:

FEB 11, 1998


Mr. Gordon Rousseau
HMT Associates, L.L.C.
1850 K Street, N.W.
Washington, D.C. 20006-3500

Dear Mr. Rousseau:

This is in response to your letter dated January 29, 1998 on behalf of CAT Contracting, Inc., requesting confirmation of the non-applicability of the Hazardous Materials Regulations (49 CFR Parts 171-180; HMR) to a cured-in-place pipe reconstruction material consisting primarily of resin-impregnated felt.

In confirmation of your understanding, this material does not meet the defining criteria for a hazardous material and is not subject to the IDv1R. This determination is based on the information provided in your letter and the understanding that the material is neither a forbidden material under the provisions of 49 CFR 173.21 nor a hazardous substance as defined in 49 CFR 171.8. If the material is packaged in a quantity wherein the styrene constituent meets or exceeds 1000 pounds, it would be regulated as a hazardous substance.

I trust this satisfies your inquiry. If we can be of further assistance, please contact us.



Edward T. Mazzullo
Director, office of Hazardous
Materials Standards

Regulation Sections

Section Subject
171.8 Definitions and abbreviations
173.21 Forbidden materials and packages