{"operation":"document","citation":"04-0184","title":"Lonza, Inc — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2004-10-14","effective_on":null,"summary":"04-0184 response to Lonza, Inc concerning 172.301.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-04-0184.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-04-0184.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-04-0184","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2004/040184.pdf","body":"<<<PAGE 1>>>\n\nof Transportation\nU.S. Department\n400 Seventh St., S.W.\nWashington, D.C. 20590\nResearch and\nAdministration\nspecial Programs\nOCT 14 2004\nMs. Felicia L. Lynch\nRef. No. 04-0184\nLonza, Inc.\n17-17 Route 208\nFair Lawn, NJ 07410\nDear Ms. Lynch:\nThis is in response to your August 6, 2004 letter requesting\nclarification of the Hazardous Materials Regulations (HMR; 49\nre-mark the consignor address on packages that were preprinted\nwith an address that is no longer a valid address for the\nshipper.\nUnder § 172.301 (d) a non-bulk package must be marked with the\nconsignor or consignee's name and address. The address must be\na valid and current address of the consignor or consignee.\nI hope this information is helpful. If you have further\nquestions, please do not hesitate to contact this office.\nSincerely.\nChief, Standards Development\nOffice of Hazardous Materials\nStandards\n040184\n172.301 (d)\n\n<<<PAGE 2>>>\n\nBAH\n$172.301 aLonza\nmarking\n04-0184\nOffice of Hazardous Materials Standards Research and Special\nPrograms Administration\n17-17 Route 208\nFair Lawn; NJ 07410, USA\nDMH-10 U.S Department of Transportation\nFelicia L. Lynch\n400 7th Street SW.,\nProduct Safety\nPerformance Chemicals\nWashington DC 20590-0001\nTel 201-794-2425\nFax 201-696-3525\nfelicia.lynch@lonza.com\n6 August 2004\nInterpretation of 49 CFR Section 172.301(d)\nTo Whom It May Concern:\nI am writing to request an interpretation regarding 49 CFR section 172.301 (d). Our company is\nmoving its headquarters and consolidating locations beginning this month. We expect to\ncomplete the move by September 2004. All product labels printed going forward will include the\nnew company address pursuant to section 301(d). However, we currently have a large quantity\nof product stocked in warehouses for shipment. This inventory is marked with the current (soon\nto be old) company address. We estimate that it will take several months for us to clear this\ninventory. Re-labeling all inventories to note the new company address would be very\nexpensive and labor-intensive. Our warehoused material is labeled in accordance with all\napplicable DOT regulations. Therefore; we request that after the company's relocation we can\ncontinue to ship our inventory without ré-labeling until existing stocks are depleted.\nPlease note that the company name and 24-hour emergency contact phone numbers will\nremain the same after the relocation. Additionally, there is a procedure in place to forward all\nmail and telephone calls to the new address for several months after the move, and we are still\nlocated in the same state. Thus, anyone attempting to contact the company based on the\naddress on the label would be able to do so.\nPlease let us know as soon as possible, whether we can continue to ship the existing inventory\nafter the relocation, and if so, for how long. Thank you for your prompt attention to this matter.\nBest regards\nFelicia L. Lynch\nexch\nProduct Safety Manager\nLonza Inc.","truncated":false,"body_characters":2941}