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Interpretation Response #99-0253 ([JL Shepherd & Associates] [Ms. Mary F. Shepherd])

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

Interpretation Response Details

Response Publish Date:

Company Name: JL Shepherd & Associates

Individual Name: Ms. Mary F. Shepherd

Location State: CA Country: US

View the Interpretation Document

Response text:

December 28, 1999

 

Ms. Mary F. Shepherd                   Ref.  No. 99-0253
Vice President
JL Shepherd & Associates
1010 Arroyo Avenue
San Fernando CA 91340-1822

Dear Ms. Shepherd:

This is in response to your letter dated September 2, 1999, regarding the use of DOT Specification 7A packagings that were designed in accordance with the requirements in effect on June 30, 1983.  I am sorry for the delay and hope this has not caused you any inconvenience.

Section 173.415(a) states that “use of Specification 7A packagings designed in accordance with the requirements of § 178.350 of this subchapter in effect on June 30, 1983 ... is not authorized after April 1, 1997.”  However, if it can be determined that a packaging originally designed in accordance with the requirements of § 178.350 in effect on June 30, 1983, meets the current requirements of 49 CFR 178.350, then the packaging would continue to be an authorized Type A packaging.

I hope this satisfies your inquiry.

Sincerely,

 

Thomas G. Allan
Senior Transportation Regulations Specialist
Office of Hazardous Materials Standards

173.415

Regulation Sections