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Interpretation Response #02-0012 ([CrossNet USA, Inc] [Cindy Seki])

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

Interpretation Response Details

Response Publish Date:

Company Name: CrossNet USA, Inc

Individual Name: Cindy Seki

Location State: OR Country: US

View the Interpretation Document

Response text:

February 5, 2002

Ms. Cindy Seki                 Reference No. 02-0012
CrossNet USA, Inc.
59 Coburg Road
Suite C
Eugene, Oregon 97401

Dear Ms. Seki:

This responds to your December 7, 2001 letter requesting clarification on § 173.29(b)(2)(ii) under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Specifically, you ask if your proposed method of cleaning fuel bottles using a cleaning product, "Slix" satisfies cleaning and purging requirements in § 173.29(b)(2)(ii).

You propose to clean and purge fuel bottles that previously contained white gasoline, kerosene, diesel and regular gasoline with a liquid alkaline cleaner, "Slix", in order to satisfy requirements in § 173.29(b)(2)(ii). These fuel bottles are used by hikers and backpackers for cooking on white gasoline stoves.

For purposes of the HMR, "cleaned and purged" means no residual hazardous material or vapor remain in a container.  The methods used to clean and purge a packaging are intentionally not defined because they vary greatly depending on the nature of the hazardous material and the type of packaging.  In some instances, a packaging can be totally emptied of hazardous material, including residue, without undergoing a cleaning process, and may be considered "cleaned and purged".  In other instances, an active cleaning process may be necessary to purge a packaging of hazardous residue.  We cannot endorse a particular cleaning product or procedure for cleaning and purging.  However, the procedure presented in your letter appears to meet the definition of "sufficiently cleaned of residue and purged of vapors to remove any potential hazard" provided any residue remaining in the fuel bottles no longer meets any of the hazard class definitions of the HMR.

I hope this answers your inquiry.

Sincerely,

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

Regulation Sections

Section Subject
173.29 Empty packagings