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Interpretation Response #00-0075 ([Innowave Incorporated] [Mr. Robert Haney])

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

Interpretation Response Details

Response Publish Date:

Company Name: Innowave Incorporated

Individual Name: Mr. Robert Haney

Location State: NE Country: US

View the Interpretation Document

Response text:

March 30, 2000

Mr. Robert Haney                 Ref No. 00-0075
Innowave Incorporated
3201 Farnam Street
Omaha, Nebraska 68131

Dear Mr. Haney:

This is in response to your letter dated March 1, 2000, and subsequent telephone conversation with
Eric Nelson of our staff regarding the proper hazard class or division for your products, FreshCUP
Bio-Cleansing Solutions, under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).

Based on subsequent information sent to this Office and additional telephone conversations with

Mr. Nelson, this Office can not determine the hazard class or division for your products.  However, it is possible that these products may meet the definition of a corrosive liquid, and therefore subject to the HMR.  We understand that these products are to be imported into the United States from Israel.

Under §173.22 of the HMR, it is the shipper's responsibility to properly class a hazardous material, and it may be necessary to test these products to determine their proper hazard class or division.  As provided by §171.12, it is the importer's responsibility to finish to the shipper and forwarding agent at the place of entry into the United States, complete information as to the requirements of the HMR.  In addition to the requirements of the HMR, international air and vessel shipments of hazardous materials are subject to the provisions of the International Civil Aviation Organization's Technical Instructions and/or the International Maritime Dangerous Goods Code.

I hope this satisfies your request.

Sincerely,

Delmer F. Billings
Chief, Standards Development
Office of Hazardous Materials Standards

173.22

Regulation Sections

Section Subject
173.22 Shipper's responsibility