{"operation":"document","citation":"99-0325","title":"Amrep, Inc. — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2000-02-01","effective_on":null,"summary":"99-0325 response to Amrep, Inc. concerning 172.301.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-99-0325.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-99-0325.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-99-0325","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/1999/990325.pdf","body":"<<<PAGE 1>>>\n\n-\n400 Seventh Street. S.W\nWashington, D.C\n20590\nFEB 1 2000\nMr. Darran T. Chase\nRef. No: 99-0325\nEnvironmental Affairs Manager\nAmrep, Inc.\n990 Industrial Park Drive\nMarietta, Georgia 30062\nDear Mr. Chase:\nThis is in response to your letter of November 30, 1999, requesting clarification of exemption DOT-E\n10232. Your understanding is that a copy of the exemption must be kept on file but that the exemption\nnumber does not have to be printed on the side of the package and that the exemption does not have to\naccompany the package when the hazardous material has been properly classed as ORM-D.\nYou are correct that this exemption specifically states that a material that has been classed as a\n\"Consumer commodity, ORM-D\" is excepted from marking the exemption number on the outer\npackaging. In addition, a copy of the exemption must be maintained at each facility where the package\nis offered or reoffered and at each facility where the packaging is being used in connection with the\ntransportation of a hazardous material. However, your understanding that a copy of the exemption is\nnot required to \"accompany\" the package is incorrect. As provided by paragraph 10 of DOT-E\n10232, a current copy of the exemption must be carried aboard each motor vehicle used to transport\npackages covered by this exemption.\nI hope this information is helpful.\nSincerely,\nman Hello\nDelmer F. Billings\nChief, Standards Development\nOffice of Hazardous Materials Standards\n990325\nIZUONI\n\n<<<PAGE 2>>>\n\nLavalle\nAamrep\n1240 est\n99-0525\nNovember 30,1999\nDirector of Hazard Materials Standards\nEdward Mazzullo\n(OHMS)\n(DHM-10)\nUS DOT/RSPA\nWashington, 20590\n400 7* St. S.W.\nRE: DOT-E 10232\nDear Mr. Mazzullo,\nI am writing for a clarification and a CFR regulation which would confirm the following information.\nOne of my customers, during a routine DOT inspection was cited for shipping materials, purchased from us\ninformation with each package.\nthat contained packaging using the exemption listed above, and not providing a copy of the exemption\nI understand when using an exemption that a copy of the exemption must be kept on file. However\naccompany the package if it falls within the guidelines of a \"Consumer Commodity\".\naccording to verbiage stated in the exemption that documentation does not have to be printed on the side or\nCan you provide some clarification on this matter?\nIf I can help with the process, please do not hesitate to call me at (770) 767-2037.\nSincerely,\nJarran I. Chas\nEnvironmental Affairs Manager\nAmrep, Inc. • 990 Industrial Park Drive • Marietta, Georgia 30062 • 770/422-2071 800/66-AMREP • Fax: 770/422-1737","truncated":false,"body_characters":2630}