Interpretation Response #01-0234 ([Mr. Lawrence W. Bierlein])

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

Interpretation Response Details

Response Publish Date: 01/23/2001

Company Name:

Individual Name: Mr. Lawrence W. Bierlein

Location State: DC Country: US

View the Interpretation Document

Response text:

JAN 23, 2001

Mr. Lawrence W. Bierlein                      Ref. No. 01-0234
2175 K Street, NW
Washington, DC 20037

Dear Mr. Bierlein:

On September 1, 2000, on behalf of Hewlett-Packard Company, you applied for an approval to ship certain inkjet cartridges as unregulated materials. This is in response to your subsequent letter of January 5, 2001, enclosing results of certain steel corrosion tests and a comparative chart on steel compositions.

We have reviewed that test data and chart, and conclude that the K02400 steel tested is sufficiently "similar to" P3 and P235 steels, as that term is used in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) and the United Nations Model Regulations on the Transport of Dangerous Goods, to be accepted for Class 8 classification purposes. We also conclude, based upon the 14-day test results you provided, that the ink in the Hewlett-Packard inkjet printer cartridges does not meet the definition of a corrosive material as set forth in 49 CFR §§ 173.136 and 173.137, and in international regulations based upon Chapter 2.Rofthe UN MoJel Regulations on the Transport of Dangerous Goods.

Accordingly, because the ink is not regulated as a hazardous material, the approval you originally requested is not necessary.

Sincerely,

Edward T. Mazzullo, Director
Office of Hazardous Materials Standards

Mazzullo:gt:dhm-l0:68553:01/17/2001
Revised
File:173.136

Regulation Sections