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Interpretation Response #99-0312 ([Tech-USA Marine Products] [Mr. Mike Campbell])

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

Interpretation Response Details

Response Publish Date:

Company Name: Tech-USA Marine Products

Individual Name: Mr. Mike Campbell

Location State: MD Country: US

View the Interpretation Document

Response text:

February 8, 2000

Mr. Mike Campbell                        Ref. No. 99-0312
Tech-USA Marine Products
800 Ryan Point Road
Accokek, MD 20607

Dear Mr. Campbell:

This is in response to your letter dated November 10, 1999, and subsequent telephone conversation with Eric Nelson of our staff regarding classing marine coating and cleaning products under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).

Based on subsequent information sent to this Office and additional telephone conversations with
Mr. Nelson, it is the opinion of this Office that your products are not subject to the requirements of the HMR.  However, under § 173.22 of the HMR, it is the shipper's responsibility to properly class a hazardous material.  Generally, manufacturers have the knowledge to properly class the materials and products they produce, although it may be necessary to enlist an outside laboratory to assist in classification process, as testing may have to be conducted to see how a product compares to the criteria for various hazard classes.

I hope this satisfies your request.



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


Regulation Sections

Section Subject
173.22 Shipper's responsibility