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Interpretation Response #09-0118R

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

Interpretation Response Details

Response Publish Date: 04-13-2010
Company Name: HOYER Global Transport BV    Individual Name: Mr. Peter Hordijk
Country: NL

View the Interpretation Document

Response text:

April 13, 2010




Mr. Peter Hordijk
Transport Safety Advisor
HOYER Global Transport BV
Boyleweg 6
3208 KA Spijkenisse
The Netherlands

Ref. No.: 09-0118R

Dear Mr. Hordijk:

This in response to your May 13, 2009 letter inquiring about the applicability of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) to import shipments to the United States. Specifically, you ask whether a bulk packaging containing a combustible liquid with a flash point of 79 ºC (174 ºF) may be imported into the United States from outside of North America using a proper shipping name followed by an identification number with an "NA" prefix and if the use of NA 1270 with the proper shipping name, "Petroleum Oil" would be appropriate for the shipment of a combustible liquid imported into the United States.

The answer is yes. Section 171.22(c) requires a material that is designated as a hazardous material under the HMR, but excepted from or not subject to international hazardous materials regulations, to be transported in accordance with all applicable requirements of the HMR. Identification numbers in the NA series are associated with descriptions not included in the international regulations. Therefore, the proper shipping name "Petroleum Oil" with the identification number NA 1270 may be used for petroleum oil that meets the definition for a combustible liquid under the HMR and is transported to, from or within the United States.

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


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


Regulation Sections

Section Subject
§ 171.22 Authorization and conditions for the use of international standards and regulations