Interpretation Response #04-0253 ([LSL Industries, Inc.] [Mr. Hussein])

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

Interpretation Response Details

Response Publish Date: 11/17/2004

Company Name: LSL Industries, Inc.

Individual Name: Mr. Hussein

Location State: IL Country: US

View the Interpretation Document

Response text:

Nov 17, 2004

Mr. Hussein                Reference No. 04-0253
Director QA/Operations
LSL Industries, Inc.
5535 N. Wolcott Avenue
Chicago, IL 60640

Dear Mr. Hitssain:

This is in response to your letter dated October 26, 2004, and subsequent conversation with a member of my staff, regarding the small quantity exception in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically you ask if “Disposable Kits” for hospitals qualify for the small quantity exception in § 173.4.

You describe two “Disposable Kits” in your letter:

(1)        The first (IV Start kit #1) contains several non-hazardous materials, and 0.67 ml of Chic rhexidine Gluconate 2% in 70% Isopropyl Alcohol, which you have classified as “Isopropyl alcohol solution, 3, UN1219, PG II.”

(2)        The second kit (IV Start kit #2) has the same configuration as the first; however, it contains 1.5 ml of the isopropyl alcohol solution.

Both of these kits meet the quantity limitation in § 173.4(a)(1)(i) of 30 ml per inner receptacle for Class 3 (Flammable) liquids. Assuming they meet the additional requirements of § 173.4, and the outside of each package is marked with the statement, “This package conforms to 49 CFR 173.4,” the “Disposable Kits” you described are excepted from any other requirements of the HMR.

I hope this information is helpful. Please contact us if you require additional assistance.

Sincerely,

John A. Gale
Chief, Standards Development
Office of Hazardous Materials Standards

172.101

Regulation Sections