U.S. Department of Transportation Rules on "Party to" Status for Reshippers on DOT-E-7887 Exemption
3/23/94: On 12/17/93, AeroTech filed a petition with the DOT for "party to" status on behalf of its reshippers in order that AeroTech's retailers and distributors could use the recently-issued fourth revision of exemption DOT-E-7887. This exemption allows the shipment of most AeroTech RMS reload kits as flammable solids. A press release dated 12/21/93 explaining the provisions of the exemption was sent to you previously. A copy of the exemption was enclosed with the press release.
This petition was made to the DOT because the exemption states that packages covered by the exemption may be reoffered for transportation "provided no modifications or changes are made to the packages...".
On 1/25/94 AeroTech received a phone call from Sandra Cureton of the Exemptions & Approvals branch of the DOT. She stated that under the DOT's interpretation of the "reoffer for transportation" portion of the exemption, reshippers can indeed break up shipments received from AeroTech and reship them in smaller packages as flammable solids. "Party to" status is not required. The only stipulation is that all the provisions of the exemption be complied with including box specifications, marking and labeling. A written interpretation was requested and received the day after this conversation. A copy is enclosed.