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Interpretation Response #01-0289 ([Enefco International, LTD.] [Mr. James F. Timmins])

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

Interpretation Response Details

Response Publish Date:

Company Name: Enefco International, LTD.

Individual Name: Mr. James F. Timmins

Location State: ME Country: US

View the Interpretation Document

Response text:

December 7, 2001


Mr. James F. Timmins                             Reference No. 01-0289

Enefco International, LTD.

1130 Minot Ave,

Auburn, ME 04211-1120

Dear Mr. Timmins:

This is in response to your letter dated November 2, 2001 regarding the applicability of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) to cleaning cards, pens, and wipes that contain 3 ml or less of isopropyl alcohol.  You state that your products contain no free flowing alcohol.

For the proper shipping name "Solids containing flammable liquids, n.o.s.,"  the Hazardous Materials Table refers you to special provision 47.  Special provision 47 excepts from the HMR sealed packets that contain less than 10 ml of a flammable liquid in Packing Group II or III when the liquid is completely absorbed onto a solid material.  Based on the information that you provided in your letter, it is the opinion of this Office that your cleaning cards, pens, and wipes are not subject to the requirements of the HMR.

I hope this information is helpful.



Edward T. Mazzullo

Director, Office of Hazardous Materials Standards


Regulation Sections

Section Subject
173.120 Class 3-Definitions