{"operation":"document","citation":"05-0315","title":"Global Logistics Services — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2006-02-03","effective_on":null,"summary":"05-0315 response to Global Logistics Services concerning 173.156.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-05-0315.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-05-0315.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-05-0315","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2005/050315.pdf","body":"<<<PAGE 1>>>\n\nFEB - 3 2006\nMs. Joan M. Boardman\nRef. No. 05-0315\nGlobal Logistics Services\nPfizer, Inc.\n1855 Shelby Oaks Drive North\nMemphis, TN 38134-7401\nDear Ms. Boardman:\nThis responds to your December 8, 2005 letter requesting clarification on marking\nrequirements for your ORM-D material under the Hazardous Materials Regulations\n(HMR: 49 CFR Parts 171-180). According to your letter, you ship your ORM-D\nmaterials in \"club pallets\" consisting of two bottles in a strong fiberboard tray. Trays are\nthen palletized and shrink-wrapped as one and transported to the consignee.\nIn accordance with § 173.156, packages of materials described as \"Consumer\ncommodity, ORM-D\" are not subject to the marking requirements prescribed in Subpart\nD of Part 172, including & 172.316, when unitized in cages, carts, boxes or similar\noverpacks, and when offered for transportation or transported by a private or contract\nmotor carrier or a common carrier vehicle under exclusive use for such service, from a\nmanufacturer to a distribution center, from a manufacturer or distribution center to a retail\noutlet, or return.\nI hope this answers your inquiry.\nSincerely,\nOffice of Hazardous Materials Standards\n173.156\n050315\n\n<<<PAGE 2>>>\n\n85 - 0315\nGlobal Transportation Compliance\nOffice of Hazardous Materials Standards\nPipeline and Hazardous Materials Safety Administration\nU.S. Department of Transportation\n400 Seventh Street, SW\nWashington, DC 20590-0001\nATTENTION: PHH-10\nPfizer manufactures a mouthwash classified as a Consumer Commodity, ORM-D which is\npackaged in 2.1 L bottles and sold to various club warehouses; i.e., Sam's, Costco, etc. in trays\non pallets. The business refers to this packaging configuration as a \"club pallet.\" This club pallet\nconfiguration consists of two bottles in a strong fiberboard tray. Trays are then palletized and\nOur understanding of the regulations (§§ 172.316, 173.25 and 173.156) and our subsequent\nconversation with your colleague, Eileen Edmonson, indicate that we may meet the ORM-D\nmarking requirements by marking the shrinkwrap as long as the mark will not become separated\nfrom the pallet; i.e., taped, covered with clear shrinkwrap, etc.\nAt your convenience, I would appreciate your confirming this understanding in writing.\ni in Bast","truncated":false,"body_characters":2274}