Interpretation Response #16-0079 ([Patterson Companies, Inc.] [Mr. Robb Boros])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Patterson Companies, Inc.
Individual Name: Mr. Robb Boros
Location State: IA Country: US
View the Interpretation Document
Response text:
November 02, 2016
Robb Boros
Regulatory Compliance Specialist
Patterson Companies, Inc.
1905 Lakewood Drive
Boone, Iowa 50036
Ref. No. 16-0079
Dear Mr. Boros:
This responds to your May 9, 2016 email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the exception for aqueous solutions of alcohol. Your questions are paraphrased and answered as follows:
Q1. Is an aqueous solution of alcohol with a small concentration of other hazardous materials eligible for the exception in § 173.150(e)(2)?
A1. No. To qualify for the exception prescribed in § 173.150(e)(2), an aqueous solution of alcohol must contain only alcohol and no other hazardous material.
Q2. If a solution described as “UN1986, Alcohols, flammable, toxic, n.o.s.” contains no more than 24 percent alcohol by volume, is no less than 50 percent water, and contains no other hazardous materials, would it be eligible for the exception in § 173.150(e)?
A2. No. The original intent of this exception was only to provide relief for alcohols that do not meet the definition of a hazard class other than Class 3 flammable liquid. When this exception was initially introduced into the HMR, the main consideration was the effect of alcohol concentration on the flashpoint of an aqueous solution. Therefore, the exception provided in § 173.150(e) is not suitable for the material described in your scenario based on the associated toxic hazard.
I trust this satisfies your inquiry. Please contact us if we can be of further assistance.
Sincerely,
Dirk Der Kinderen
Chief, Standards Development Branch
Standards and Rulemaking Division
173.150(e)(2), 173.150(e)