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Interpretation Response #08-0118

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date: 07-23-2008
Company Name: Seaboard Marine Ltd.    Individual Name: Mr. John Plasencia
Location state: FL    Country: US

View the Interpretation Document

Response text: July 23, 2008

Mr. John Plasencia
Seaboard Marine Ltd.
8001 NW 79 Avenue
Miami, FL 33166

Ref. No. 08-0118

Dear Mr. Plasencia:

This is in response to your request for clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) regarding aerosols that are shipped in accordance with the International Maritime Dangerous Goods Code (IMDG Code). Specifically, you ask whether aerosols with a capacity of more than 1 L may be transported to, from or within the United States in accordance with the IMDG Code if the aerosols meet the conditions in § 171.23(b)(1).

Provided the shipment also conforms to the applicable requirements in §§ 171.22, "Authorization and conditions for the use of international standards and regulations," and 171.25, "Additional requirements for the use of the IMDG Code," aerosols shipped under the proper shipping name "Aerosol," UN1950, meeting the conditions in § 171.23(b)(1)may be transported to, from or within the United States under the IMDG Code.

I hope this information is helpful. Please contact this office if you have additional questions.


Hattie L. Mitchell
Chief, Regulatory Review and Reinvention
Office of Hazardous Materials Standards

171.22, 171.23, 171.25, 171.8

Regulation Sections

Section Subject
§ 171.25 Additional requirements for the use of the IMDG Code