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Interpretation Response #00-0077 ([Inkware] [Mr. John Tune])

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

Interpretation Response Details

Response Publish Date:

Company Name: Inkware

Individual Name: Mr. John Tune

Location State: NV Country: US

View the Interpretation Document

Response text:

March 17, 2000

Mr. John Tune                Ref. No. 00-0077

Director, Customer Services

Inkware

1944 Parna Lane

Las Vegas, NV 89119

Dear Mr. Tune:

This is in response to your March 6, 2000 letter concerning the domestic and international shipment of printing ink and related products by aircraft.  You state the products have a flash point above 141 degrees Farenheit  and are shipped in the following configurations: one case of 12 one-quart bottles, one box of 4 one-gallon bottles, and one five-gallon plastic pail.

Under 49 CFR 173.120(b)(1), a "combustible liquid" is defined as a material that has a flash point above 60.5 degrees Celcius  (141degrees Farenheit ) and below 93 degrees Celsius  (200 degrees Farenheit) that does not meet the definition of any other hazard class under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  A combustible liquid that does not meet the definition in §171.8 of a hazardous waste, hazardous substance, or marine pollutant and that is packaged in a non-bulk packaging, i.e., a packaging having a liquid capacity of 450 L (119 gallons) or less, is not subject to the requirements contained in HMR.  See §173.150(f)(2). Such a material also is not regulated under the requirements of the International Civil Aviation Organization's Technical Instructions for the Safe Transport of Dangerous Goods by Air.  If the combustible liquid is a hazardous substance or hazardous waste and is intended for transportation by air, it must be offered for transportation in conformance with the requirements in ' 173.150(f)(3). Also see §171.1 1.

I hope this satisfies your request.  Please contact us if we can be of further assistance.

Sincerely,

Hattie L. Mitchell, Chief

Regulatory Review and Reinvention

Office of Hazardous Materials Standards

173.150(f)(2)

Regulation Sections