04-0022
04-0022
Page 1of Transportation U.S. Department 400 Seventh Street, S.W. special Programs Research and Washington. D.C. 20590 Administration January 29, 2004 Major Mark P. Wyrosdick Chief of Safety Ref. No. 04-0022 Department of the Army Military Surface Deployment and Distribution Command Operations Center 661 Sheppard Place Fort Eustis, VA 23604-1644 Dear Major Wyrosdick: Duane Pfund regarding the hazardous material documentation requirements of the IMDG Code This is in response to your letter dated January 28, 2004 and subsequent conversations with Mr. for multi-modal shipments. Specifically you ask if the "Shipper's Declaration for Dangerous the IMIDG Code. Goods" form utilized for the air mode of a shipment is authorized for onward movement under In accordance with the IMDG Code Amendment 31, paragraph 5.4.1.2.1 "A dangerous goods transport document may be in any form, provided it contains all of the information required by the provisions of this Code." It is not the intent of the IMDG Code to restrict the form of the required dangerous goods transport documentation. Therefore, the IMDG Code allows for the use of the "Shipper's Declaration for Dangerous Goods" form to the extent that the form meets all information requirements of the Code. However, this also does not prevent individual competent authorities or individual vessel carriers from applying more restrictive provisions, as they deem necessary. I hope this answers your inquiry. Sincerely, Robert A. Richard International Standards Coordinator for Hazardous Materials Safety 040022#
Page 2MILITARY SURFACE DEPLOYMENT-AND DISTRIBUTION COMMAND DEPARTMENT OF THE ARMY OPERATIONS CENTER REPLY TO RT EUSTIS, VA 23604-16 31 SHEPPARD PLAI ATTENTION OF Safety Branch January 28, 2004 Mr. Duane Pfund Office of Ilazardous Materials Transportation Research and Spocial Programs Administration U.S. Department of Transportation 400 Seventh Street, SW Washington, DC 20590 URGENT PLEASE EXPEDITE Request for Formal Letter of Interpretation Re: International Maritime Organization (IMO) International Maritime Dangerous Goods Code (IMDGC) Chapter 5.4. Dear Sir: office issue a Formal Letter of Interpretation related to our reference above. The following file On behalf of the United States Department of Defense (DOD), we are requesting your number has been assigned: File Number: 28-04 (0128) Re: USTC Letter 22 APR 2003 Proponent: US DOD We are petitioning you to assist us by providing guidance for our customers engaged in international commerce shipping hazardous materials within the purview of International Maritime Organization's body of codified standards. Essentially, our request focuses upon clarification of the IMO position relative to the documentation requirements for multimodal movement of HAZMAT as stated in Chapter 5.4, paragraph 5.4.1.3.3 of the IMDGC. "When an existing transport or shipping document, or cargo handling form, these specimen declaration forms (5.4.5) may be used." cannot be used for the purposes of dangerous goods documentation for multimodal transport.#
Page 3-2- dugani@sddc.army.mil, Directorate of Plans, Readiness and Mobilization, Safety Team, Military 'This request is submitted by Mr. Joseph P. Dugan, phone 757 878-8294, e/mail Eustis, VA 23604-1644. Surface Deployment and Distribution Command, Operations Center, 66l Sheppard Place, Fort Sincerely, Mach Po Wigorclik Mark P. Wyrosdick Chief of Safety Major, US Air Force#
Page 4UNITED STATES TRANSPORTATION COMMAND SCOTT AIR FORCE BASE, ILLINOIS G2225-5357 508 SCOTT DR MEMORANDUM FOR HQ MTMC/MTDC-OP 22 APR 2003 ATTENTION: Mr. C.E. Radford FROM: TCJ5-SD SUBJECT: Request for Official International Maritime Organization (IMO) Clarification materials (HAZMAT), obtain official memorandum from Department of Transportation Request your office, as the DOD proponent for the handling and movement of hazardous HAZMAT as stated in Chapter 5.4., paragraph 5.4.1.3.3 of the International Maritime Dangerous clarifying the IMO position on documentation requirements for multimodal movement of International Standards Coordinator (attached). Reference e-mail has been stated as official Goods Code. Reference 26 February 2003, 1 1:08 A.M. e-mail from Mr. Duane Pfund. DOT hazardous shipments prepared for shipment by air diverted to surface, i.e. vessel, for onward guidance but an official memorandum is requested to further support the execution of shipping movement to final destination. Mich GEORGE R. RAXE Chief, Strategic Distribution Branch Strategic Initiatives Division Attachment 19 - 26 February e-mail string cc: USEUCOM 14PM Printed on recycled paper#
This material provides agency context. It does not replace binding regulatory text, and its legal effect depends on the underlying authority and facts.