Interpretation Response #98-0554 ([Department of Transportation] [R. I. Reinemann])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Department of Transportation
Individual Name: R. I. Reinemann
Location State: GA Country: US
View the Interpretation Document
Response text:
JUN 3, 1998
R. I. Reinemann
Lieutenant, U.S. Coast Guard
Department of Transportation
222 W. Oglethorpe Ave., Suite 402
Savannah, GA 31401
Dear Lieutenant Reinemann:
This is in response to your letter concerning the transportation of ORM-D materials by water borne traffic. Specifically, you are requesting clarification concerning the use of the ORM-D classification for international shipments (i.e., outside of the U.S. and its territories) under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).
Entries proceeded by a "D" in column one of the Hazardous Materials Table (HMT) may not be suitable for international shipments under the provisions of international regulations (e.g., International Maritime Organization Dangerous Goods Code (IMDG» as outlined in § 172.101(b)(3) of the HMR. The ORM-D designation is suitable for domestic shipments, as specified by the letter "D" in column one of the HMT. Since there is no provision for the ORM-D classification in the IMDG regulations, a different shipping name must be chosen which complies with IMDG regulations. Please note that vessel shipments within the U.S. may conform to the HMR.
I hope this answers your inquiry. If we can be of further assistance, do not hesitate to contact us.
Sincerely,
Delmer F. Billings
Chief, Regulations Development
Office of Hazardous Materials Standards