Guidanceguidance
99-0312
Tech-USA Marine Products — Hazardous Materials Safety Interpretation
Current as of source date Government source
RegulusPipeline researchRegulusPipeline research99-0312
Page 1of Transportation U.S. Department 400 Seventh Street, S.W. Washington, D.C. 20590 Research and ldministratio pecial Program FEB 8 2000 Mr. Mike Campbell Tech-USA Marine Products Ref. No. 99-0312 800 Ryan Point Road Accokek, MD 20607 Dear Mr. Campbell: This is in response to your letter dated November 10, 1999, and subsequent telephone conversation with Eric Nelson of our staff regarding classing marine coating and cleaning products under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Based on subsequent information sent to this Office and additional telephone conversations with Mr. Nelson, it is the opinion of this Office that your products are not subject to the requirements of the HMR. However, under § 173.22 of the HIMR, it is the shipper's responsibility to properly class a hazardous material. Generally, manufacturers have the knowledge to properly class the materials and products they produce, although it may be necessary to enlist an outside laboratory to assist in classification process, as testing may have to be conducted to see how a product compares to the criteria for various hazard classes. I hope this satisfies your request. Sincerely, Suhan Bellio Delmer F. Billings Chief, Standards Development Office of Hazardous Materials Standards 173.22 990312#
Page 2• : : Nelso 1/3.22 • F 99-0312 FAX Cover Sheet To: Department of Iransportation Hazardous Materiais Information Center Att: Erik Phone 800.467.4922 FAX 202.366.3012 From: Tech-USA Marine Products Mike Campbell Phone 301.292.3025 FAX 301.292.6283 Included in this transmission, please find the Material Safety Data Sheet for the following two products Allguard Teakguard - a protective coating for marine teak wood Allguard Teakguard Teak Cleaner - a cleaner for marine teak wood I need to determine the transportation classification for these items so that UPS or the Post Office can tell us if there is any restriction on the shipping of these products. Sincerely, Mike Campbell ased 6582926218SWJ W068: 1185-82-005 : Ra zues#
This material provides agency context. It does not replace binding regulatory text, and its legal effect depends on the underlying authority and facts.