{"operation":"document","citation":"06-0188","title":"Hazardous Materials Training Compliance — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2006-09-08","effective_on":null,"summary":"06-0188 response to Hazardous Materials Training Compliance concerning 173.422.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-06-0188.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-06-0188.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-06-0188","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2006/060188.pdf","body":"<<<PAGE 1>>>\n\n400 Seventh Street, S.W.\nWashington, D.C. 20590\nPipeline and\nHazardous Materials Safety\nAdministration\nSEP\n8 2006\nMr. Philip C. Rieke\nRef. No. 06-0188\n7109 West Wernett Road\nHazardous Materials Training Compliance\nPasco, WA 99301\nDear Mr. Rieke:\nThis is in response to your letter requesting clarification of the shipping paper and marking\nrequirements under the Hazardous Materials Regulations (HMR; 49 CPR Parts 171-180)\nthe appropriate shipping description for limited quantity shipments for which shipping papers\napplicable to limited quantities of Class 7 (radioactive) materials. Specifically, you ask about\nare required and package marking requirements for excepted packages.\nSections 173.421, 173.424, 173.426 and 173.428 contain requirements for transporting\nexcepted quantities of Class 7 (radioactive) materials, including limited quantities. If you are\npreparing packages for shipment in accordance with these sections, you may take advantage\nof the additional exceptions in § 173.422. The introductory paragraph of § 173.422 excepts\nsuch packages from all other HMR requirements except for the requirements in § 173.422\nand the applicable packaging section (such as § 173.421).. Unless the package contains a\nshipping paper is required. In accordance with § 172.203(b), for a limited quantity shipment\nClass 7 (radioactive) material that is also a hazardous substance or hazardous waste, no\nthat also is a hazardous substance or hazardous waste, when the words \"limited quantity\" are\npart of the proper shipping name, you need not repeat the words \"limited quantity\" following\nthe basic description.\nWith respect to the identification number of the material being transported, you are correct\nthat it's marking on the package is not required to be placed within a square-or-point border\nfor packages prepared for shipment as described in the above paragraph.\nI hope this information is helpful. Please contact this office if you have additional questions.\nSincerely,\nHattie L. Mitchell\nOffice of Hazardous Materials Standards\nChief, Regulatory Review and Reinvention\n173.422\n060188\n\n<<<PAGE 2>>>\n\nRug 02 06 02:40p\nPhilip C. Rieke\n(509)544-0650\np.1\nHeardes\n7109 West Wernett Road, Fasco, WA 99301\nMatricis\nTrai ting\n509-532-7286/509-544-0653 fas\nhazmattc.@att.net\nTrespartar\n&\nCarginna\nConsuting\nMIntyre\n5172.315\nAugust 2, 2006\nMr. Edward T. Mazzullo, Director\n§173.422(a)\nPHH-10\nOffice of Hazardous Materials Standards\nRAM\n4007 Street SW\n06-0188\nWashington, DC 20590-0001\nDear Mr. Mazzullo,\nIn the past couple of years, there have been a number of regulatory changes affecting the shipment of Class 7\n(radioactive) materials in Subpart I of Part 173 that might have had an affect on communication regulations in\nPart 172, but there weren't necessarily changes in Part 172 in response.\nRecently there has been some confusion specific to shipments of limited quantities of Class 7 materials and how\nrequirement on a shipping paper and then also in 172.315 with the fairly new marking requirement for limited\nthey should be prepared. The conflict that seems to have arisen starts in Part 172.203(b) with an additional\nmust comply with these sections. Others, like me, wonder if that is a correct understanding or possibly a\nquantities. Neither of these sections except shipments of Class 7 materials leading some to believe that they\nconflict? Would these two sections apply to Class 7 limited quantities or not?\nI know that for many years, limited quantities of Class 7 materials were specifically excepted from any and all\nshipping paper requirements and that certain types of shipments only in the past few years now do require\nyears never required shipping papers for the limited quantities of Class 7, there was certainly no need to speak\nshipping papers (ltd qty that is also a hazardous substance or hazardous waste). Since the regulations for many\nto whether Class 7 shipments had to apply 172.203(b) or were excepted from it. If these Class 7 shipments\nalready includes the phase \"limited quantity of material\" which no other proper shipping name for any other\nwere to have to comply with 172.203(b), there would be a duplication since the Class 7 proper shipping name\nhazard class or division of material does.\nIn terms of the marking requirements, there seems to be a fairly clear path for 172.315 not 1o apply to Class 7\nearliest convenience.\nPlease clarify these two sections if you would and let me know PHMSA's stance whatever \"hat might be at your\nSincerely,\nChis (. Keti\nPhilip\n. Rieke, Owner\nHMTC Training & Consulting","truncated":false,"body_characters":4560}