{"operation":"document","citation":"14-0195","title":"The Clorox Company — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2015-04-02","effective_on":null,"summary":"14-0195 response to The Clorox Company concerning 171.8, 172.304, 172.315, 173.156, 173.25.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-14-0195.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-14-0195.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-14-0195","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2015/140195.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department of Transportation\nSafety Administration\nPipeline and Hazardous Materials\nWashington, DC 20590\n1200 New Jersey Avenue, SE\nAPR 0 2 2015\nMr. Maurice C. Carson\nHazardous Materials Transportation Specialist\nThe Clorox Company\n1000 Cobb Place Boulevard NW, Suite 100\nKennesaw, GA 30144\nReference No. 14-0195\nDear Mr. Carson:\nThis is in response to your recent letter requesting clarification of the Hazardous Materials\nRegulations (HMR; 49 CFR Parts 171-180), and your October 14, 2014, conversation with\na member of our Hazardous Materials Information Center staff, applicable to the limited\nquantity marking prescribed in § 172.315.\nIn your letter, you state that your company places bleach products in packages that comply\nwith § 173.156 on a pallet, and then surrounds these packages in a shrink-wrap overpack.\nYou also state your company places the § 172.315 limited quantity marking only on the\nouter surface of the shrink wrap. Further, you state your company was cited for not placing\nthe limited quantity mark on each package that complied with § 173.156. You ask if the\nHMR require this mark to be placed on the outer surface of each limited quantity package\nthat is transported internationally by vessel.\nFor those bleach products that meet the definition of a hazardous material and comply with\nthe HMR's limited quantity regulations, the answer is yes. The HMR require markings\nprescribed in 49 CFR Part 172, Subpart D, which includes the § 172.315 limited quantity\nmarking, to be printed on or affixed to the surface of a completed package that contains a\nhazardous material (see § 172.304(a)(1)). In your example, the completed package is the\nbox of hazardous material bleach products that complies with § 173.156, and the overpack\nis the shrink wrap (see the definitions for \"package\" and \"overpack\" in § 171.8). If the\nmarkings the HMR require are visible through the shrink wrap, they are not required to be\nrepeated on the outer surface of the overpack (see § 173.25(a) (2))).\nI hope this satisfies your request.\nSincerely,\nTAlenn Frostes\nT. Glenn Foster\nChief, Regulatory Review and Reinvention Branch\nStandards and Rulemaking Division\n\n<<<PAGE 2>>>\n\nEdmorson\n$173.156\nLimited Quanity\nDodd, Alice (PHMSA)\n14-0195\nSent:\nFrom:\nCiccarone, Michael CTR (PHMSA)\nTuesday, October 14, 2014 4:07 PM\nTo:\nHazmat Interps\nSubject:\nFW: Letter of Interpretation\nShante and Alice,\nPlease submit this for a formal letter of interpretation. Mr. Carson spoke with Adam Lucas in the HMIC.\nThanks,\nMike\nFrom: Maurice Carson [mailto:Maurice.Carson@clorox.com]\nTo: INFOCNTR (PHMSA)\nSent: Tuesday, October 14, 2014 12:49 PM\nSubject: Letter of Interpretation\nGood day,\nI am requesting an official Letter of Interpretation for the following Limited Qty Ruling.(173.156)\nThe Clorox Services Company has been shipping Bleach products for years internationally, without any\nincidents. Recentlý one of our containers was sent back to a distribution center to have each BOX(772)\nindividually labeled with the New Limited Qty Marking. This was done at a considerable cost as you might\nimagine. We have always Palletized, Shrink-wrapped and placed on one side the Limited Qty marking and also\nthe wording OVERPACK.(173.25 a) This has been done, to the lack of visibility of each box. Your timely help\nwith the clarification of this will be greatly appreciated. Thank you.\nMaurice C. Carson\nHazardous Material Transportation Specialist\nKennesaw, GA.30144\n678-831-2117(WK)\n678-956-9140(Cell)\n678-831-2053(Fax)\nSupport A Soldier\nTHE CLOROX COMPANY\nKINGŚFORD\nFresty\nMasterpiece\nCLOROX\nSABRITA GLADI\npoetty\nfor the use of the intended recipients). If the reader of this message is not the intended recipient(s), you are notified that\nThis e-mail (including any attachments) may contain information confidential to The Clorox Company and is intended only\nyou have received this message in error and that any review, dissemination, distribution or copying of this message is\n1\n\n<<<PAGE 3>>>\n\n., *\nimmediately.\nstrictly prohibited. If you have received this message in error, please delete this message and notify the sender\n2","truncated":false,"body_characters":4129}