Interpretation Response #99-0044 ([Fire Star Electric Match] [Mr. Jerry F. Dyben])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Fire Star Electric Match
Individual Name: Mr. Jerry F. Dyben
Location State: IN Country: US
View the Interpretation Document
Response text:
May 14,1999
Mr. Jerry F. Dyben Ref. No. 99-0044
Fire Star Electric Match
Post Office Box 533
New Haven, IN 46774
Dear Mr. Dyben:
This is in response to your letter dated February 16, 1999, requesting clarification on the proper classification and shipment of your rocket motor ignitor kit under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).
Under 173.22 of the HMR, it is the shipper’s responsibility to properly classify and describe a hazardous material. This Office generally does not perform this function. However, we provide assistance when we have the information available. Based on the information provided in your letter, your rocket motor ignitor kit contains two products:
Bottle A
6.1 grams of magnesium powder
2.7 grams of titanium sponge powder
8.8 grams of coating solution
Bottle B (High-densitv Polvethvlene)
17 grams of potassium perchlorate with vermiculite
According to your letter and the HMR, magnesium powder is a Division 4.3 dangerous when wet material, titanium sponge powder a Division 4.1 flammable solid material, and coating solution a Class 3 flammable liquid. If your materials meet any of the hazard class defining criteria in Part 173, they are subject to the HMR.
Based on the quantities of hazardous materials described in your rocket motor ignitor kit, and provided all provisions are met, your product may be shipped under the small quantities exception in 173.4 of the HMR. In order to ship as a consumer commodity, materials must meet the limited quantity provisions for that Hazard class in Part 173 and the definition of a consumer commodity in 171.8 of the HMR. Both Bottle A and B may be shipped within the same box, provided they are compatible and will not react dangerously.
I hope this answers your inquiry.
Sincerely,
Delmer F. billings
Chief, Standards Development
Office of Hazardous Materials Standards
173.22
Regulation Sections
| Section | Subject |
|---|---|
| 173.22 | Shipper's responsibility |