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Interpretation Response #99-0325 ([Amrep, Inc.] [Mr. Darran T. Chase])

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

Interpretation Response Details

Response Publish Date:

Company Name: Amrep, Inc.

Individual Name: Mr. Darran T. Chase

Location State: GA Country: US

View the Interpretation Document

Response text:

February 1, 2000


Mr. Darran T. Chase             Ref.  No: 99-0325
Environmental Affairs Manager
Amrep, Inc.
990 Industrial Park Drive
Marietta, Georgia 30062

Dear Mr. Chase:

This is in response to your letter of November 30, 1999, requesting clarification of exemption DOT-E 10232.  Your understanding is that a copy of the exemption must be kept on file but that the exemption number does not have to be printed on the side of the package and that the exemption does not have to accompany the package when the hazardous material has been properly classed as ORM-D.

You are correct that this exemption specifically states that a material that has been classed as a "Consumer commodity, ORM-D" is excepted from marking the exemption number on the outer packaging.  In addition, a copy of the exemption must be maintained at each facility where the package is offered or reoffered and at each facility where the packaging is being used in connection with the transportation of a hazardous material.  However, your understanding that a copy of the exemption is not required to "accompany" the package is incorrect.  As provided by paragraph 10 of DOT-E 10232, a current copy of the exemption must be carried aboard each motor vehicle used to transport packages covered by this exemption.

I hope this information is helpful.



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


Regulation Sections

Section Subject
172.301 General marking requirements for non-bulk packagings