{"operation":"document","citation":"15-0180","title":"COSMO International Corporation — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2015-12-08","effective_on":null,"summary":"15-0180 response to COSMO International Corporation concerning 171.22, 171.23, 171.25.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-15-0180.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-15-0180.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-15-0180","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2015/150180.pdf","body":"<<<PAGE 1>>>\n\nof Transportation\nU.S. Department\nWashington, D.C. 20590\n1200 New Jersey Avenue, SE\nMateriais Safety\nPipeline and Hazardous\nAdministration\nDEC 0 8 2015\nPatricia M. Sobel\nRegulatory Manager\nCOSMO International Corporation\n601 Fairway Drive\nDeerfield Beach, FL 33441\nRef. No. 15-0180\nDear Ms. Sobel:\nThis responds to your letter of August 8, 2015 and subsequent telephone conversation with a\nmember of my staff requesting clarification of the Hazardous Materials Regulations (HMR;\n49 CFR Parts 171-180) and the International Maritime Dangerous Goods (IMDG) Code\napplicable to United Nations (UN) identification number (ID) markings for export shipments.\nWith your request, you provided a shipping paper that indicates the shipment contained a\nvariety of material identified as \"UN3082, Environmentally hazardous substance, liquid,\nn.o.s.,\" as well as a material identified as \"UN1760, Corrosive liquid, n.o.s.\" You state these\nmaterials were offered in non-bulk packaging not meeting any of the conditions listed in\n5.3.2.1.1 of the IMDG Code that would require marking of the UN ID numbers on cargo\ntransport units. Specifically, you ask for confirmation of your understanding that the display\nof UN ID numbers is not required on your dangerous goods containers per the requirements of\nthe IMDG Code.\nBased on the shipping paper and scenario you have provided, it is the opinion of this Office\nthat your understanding is correct. In accordance with 5.3.2.1.1 of the IMDG Code, your\ndangerous goods container, as described, would not be required to display UN ID numbers.\nProvided all or part of the movement is by vessel, hazardous materials may be offered for\ntransportation or transported to, from, or within the U.S. in accordance with the requirements\nof the IMDG Code and all applicable requirements of Part 171, Subpart C. See §§ 171.22,\n171.23, and 171.25.\nI hope this answers your inquiry. If you need additional assistance, please contact this Office\nagain.\nSincerely,\nActing Chief, Standards Development Branch\nStandards and Rulemaking Division\n\n<<<PAGE 2>>>\n\nResto\n172.332\nmachingo\nCOSMO\n15.0186\nAugust gth\n, 2015\nUS Department Of Transportation\nMaritime Administration - West Building\n1200 New Jersey Avenue, SE\nWashington, DC 20590\nRe.: Marking Requirements of cargo transport units vs local requirements (other countries)\nDear Sir or Madam,\nWe are in the need of a formal written answer / response to the following situation:\nOur corporate office in Peru is requesting our help with the marking of all containers exported from the\nUS, specifically they want us to display the UN Numbers corresponding to all the classes of dangerous\ngoods loaded inside the container(s).\nAccording to IMDG 5.3.2.1, we are only required to display the UN Numbers in consignments described\nunder 5.3.2.1.1, none of the situations described on 5.3.2.1.1 would apply to our handling operations.\nWe have also reviewed 5.3.2 UN Recommendations on the transport of dangerous goods and none.\nwould either apply. We follow all the other placarding requirements according to IMDG.\nPlease be kind enough to confirm if we are correct with our determination and if there would be any\ncircumstances in which we could assist our corporate office with this request. Our goal is to provide\nthem with an official confirmation so they pursue the support from their transportation partners /\ncontractors in observing national requirements.\nThank you and we look forward to your reply.\nBest regards,\nPatricia M. Sobel\nRegulatory Manager\n6 00 Drive Decerti Reach: 3300\nPor 1950) /98 450033% 000 798 91•","truncated":false,"body_characters":3590}