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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #01-0245 ([National Toxicology Program Archives] [Mr. J. Keith Connelly])

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

Interpretation Response Details

Response Publish Date:

Company Name: National Toxicology Program Archives

Individual Name: Mr. J. Keith Connelly

Location State: NC Country: US

View the Interpretation Document

Response text:

November 16, 2001


Mr. J. Keith Connelly                             Reference  No. 01-0245
Chemical Hygiene Officer NTP Archives
National Toxicology Program Archives
P.O. Box 13566
Research Triangle Park, NC 27709

Dear Mr. Connelly:

This responds to your September 14, 2001 letter and subsequent telephone conversation with me asking whether the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) apply to a rail or motor vehicle shipment of non-infectious rodent tissue transported with a 70% ethyl alcohol solution (flashpoint of 40°F).  The specimen and 50 ml of ethyl alcohol are in a 4 ½  ml thick, heat-sealed polyethylene bag that is packed in another heat-sealed polyethylene bag and placed with about 60 additional specimens prepared in the same manner inside of a non­specification fiberboard box.  Each box will contain approximately 3 L (.8 gallon) of ethyl alcohol and weigh less than 30 kg (66 pounds).

Non-infectious animal tissue is not regulated under the HMR.  However, the ethyl alcohol solution is regulated as a Class 3 (flammable) material with the shipping description “Ethyl alcohol, 3, UN 1170, PG II.” A Class 3 material may be transported as a limited quantity in conformance with the provisions of § 173.150(b) of the HMR.  A specification pac is not required for a shipment of a limited quantity.  From your description, it appears that the packaging you propose for shipment of the specimens conforms to the provisions of the § 173.150(b) and, thus, may be used to transport the ethyl alcohol solution as a limited quantity.

A shipping paper that meets the requirements contained in Part 172, Subpart C, must accompany the package and include the text “Limited Quantity” or “Ltd Qty” after the basic description.  The text “Ethyl alcohol” and other applicable information must be marked on the package as prescribed in Part 172, Subpart D. Further, any employee performing a function that affects the safety of this package in transportation must receive HMR training (see Part 172, Subpart H).  Packages prepared
according to the requirements in § 173.150(b) are excepted from the HMR’s labeling and placarding requirements.

I hope this information is helpful.



John A. Gale
Transportation Regulations Specialist
Office of  Hazardous Materials Standards


Regulation Sections

Section Subject
173.134 Class 6, Division 6.2-Definitions and exceptions