Interpretation Response #09-0298 ([Chemical Solutions] [Mr. Neil M. Canter])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Chemical Solutions
Individual Name: Mr. Neil M. Canter
Location State: PA Country: US
View the Interpretation Document
Response text:
January 15, 2010
Mr. Neil M. Canter
Chemical Solutions
1836 Patricia Avenue
Willow Grove, PA 19090
Ref. No. 09-0298
Dear Mr. Canter:
This responds to your December 3, 2009 request for clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if you may ship your windshield washer fluid as a Consumer Commodity, ORM-D material, as authorized under
§ 173.150.
According to your letter, your product contains between 30-100% of methanol and 1-5% of propylene glycol. The material meets the definition for a Class 3 material and is most appropriately described as "Flammable liquid, n.o.s. (methanol), UN 1993, III."
For purposes of the HMR, a "consumer commodity" is defined as a material that is packaged and distributed in a form intended or suitable for resale through retail sales agencies for individual personal care or household use. If your product is packaged and suitable for retail sale and conforms with the limited quantity provisions in §173.150, you may rename your product "Consumer Commodity" and re-class the product as an ORM-D material.
I hope this answers your inquiry. If you need further assistance, please contact this Office at
202-366-8553.
Sincerely,
Charles E. Betts
Chief, Standards Development
Office of Hazardous Materials Standards
173.150
Regulation Sections
| Section | Subject |
|---|---|
| 173.150 | Exceptions for Class 3 (flammable and combustible liquids) |