{"operation":"document","citation":"10-0246","title":"W.E. Train Consulting — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2010-12-17","effective_on":null,"summary":"10-0246 response to W.E. Train Consulting concerning 173.24a.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-10-0246.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-10-0246.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-10-0246","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretations/2010/100246.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department of Transportation 1200 New Jersey Ave, SE\nPipeline and Hazardous Materials\nWashington, D.C. 20590\nSafety Administration\nDEC 1 7 2010\nMr. W. Eugene Sanders\nManager\nW.E. Train Consulting\n8710 W. Hillsborough Ave #112\nTampa, FL 33615\nRef. No.: 10-0246\nDear Mr. Sanders:\nThis responds to your November 2, 2010 letter requesting clarification of the Hazardous\nMaterials Regulations (HMR; 49 CFR Parts 171-180). You state that in a previous letter of\ninterpretation issued by PHMSA (06-0016), we permitted the use of an authorized single\npackaging, which was tested and marked for liquid hazardous materials, to contain inner\nreceptacles that were compatible with the lading provided the inner receptacles would not\nadversely impact the level of performance of the packaging. Specifically, you ask whether this\ninterpretation of the HMR continues to be in compliance.\nThe answer is yes. An authorized single packaging which is tested and marked for liquid\nhazardous materials may contain inner receptacles that are compatible with the lading provided\nthe inner receptacles do not adversely impact the level of performance of the packaging. This\nconfiguration continues to comply with the HMR. Furthermore, the packaging would remain\nmarked as a single packaging and be to subject to all requirements of the subchapter as a single\npackaging.\nI trust this satisfies your inquiry. Please contact us if we can be of further assistance.\nSincerely,\nr---7~~?'&~~--\nT. Glenn Foster\nChief, Regulatory Review and Reinvention Branch\nStandards and Rulemaking Division\n\n<<<PAGE 2>>>\n\nNl tl<tLS\n§ 113. 2~~\nr>acJ:~.aj J~g s\nlCJD2 tJ~ NOV 222010\nCONSULTING\n02 November 2010\nJohn A. Gale\nChief, Standards Development\nOffice of Dangerous Goods Standards\nPHMSA, U.S. Department of Transportation\n1200 New Jersey Avenue, SE\nWashington, DC 20590\nDear Mr. Gale,\nThis letter seeks further clarification of the regulatory requirements related to your letter of\ninterpretation, Ref. No. 06-0016, attached.\nA dangerous good intended for international air shipment is placed in an authorized, non-bulk, single\npackaging, but as per the aforementioned letter of interpretation, the dangerous good is further\ncontained in compatible inner receptacles. The package remains marked as a single packaging, again\nper the letter of interpretation. Please confirm that, consistent with the specification package markin&\nthe package is still a single package, subject to the single package air shipment limits and Packing\nInstructions (PI), and when described on shipping documents may declare the single package PI.\nWe are aware of a counter-argument, with which we do not agree, that says the configuration is not a\nsingle package, but a combination package. Please be aware that a determination that the shipping\ndocuments must declare a combination package PI will almost certainly be noted by carriers as a conflict\nwith the single package specification mark, and result in rejection of the shipment.\n::~re~ iL...\nW. Eugene Sanders III\nManager, W.E. Train ConSUlting\n8710 W. Hillsborough Avenue #112\nTampa, FL 33615 USA\nGene@WEtrainConsultlng.com\n(412) 779-5151","truncated":false,"body_characters":3153}