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Interpretation Response #99-0159 ([Sea-Land Services, Inc.] [Mr. Prabhu Natarajan])

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

Interpretation Response Details

Response Publish Date:

Company Name: Sea-Land Services, Inc.

Individual Name: Mr. Prabhu Natarajan

Location State: NC Country: US

View the Interpretation Document

Response text:

August 9, 1999


Mr. Prabhu Natarajan                        Ref. No. 99-0159
Sea-Land Services, Inc.
6000 Carnegie Boulevard
Charlotte, NC 28209

Dear Mr. Natarajan:

This is in response to your letter of November 4, 1998, and your phone conversation with Mr. Brian Robinson of the U.S. Coast Guard concerning the subsidiary risk label for azodicarbonamide which is a Division 4.1 material.  You have indicated that the material has been classified outside the United States and the competent authority of the country of origin has provided a dispensation from the explosive subsidiary risk in accordance with the provisions of the International Maritime Dangerous Goods (IMDG) Code.

Section 171.12(b) of the U.S. Hazardous Materials Regulations (HMR; 49 CFR Parts 100-185) allows the alternative use of the IMDG Code subject to certain conditions and limitations.  None of those conditions and limitations restrict the use of the IMDG Code in this situation.  Consequently, azodicarbonamide shipped in accordance with the IMDG Code as you have described is acceptable.  It is also worth noting that the special provisions which you mention in your letter (Special Provisions 38 and 53 in § 172.102) address provisions similar (although stated differently) to those contained in the IMDG Code for this material.

I hope this satisfies your request.



Delmer F. Billings
Chief, Standards Development
Office of Hazardous Materials Standards


Regulation Sections

Section Subject
171.12 North American Shipments