Interpretation Response #02-0115 ([Zee Medical, Inc.] [Kevin Lloyd])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Zee Medical, Inc.
Individual Name: Kevin Lloyd
Location State: CA Country: US
View the Interpretation Document
Response text:
May 15, 2002
Mr. Kevin Lloyd Reference No. 02-0115
Director, Regulatory Affairs
22 Corporate Park
Zee Medical, Inc.
Irvine, CA 92606
Dear Mr. Lloyd:
This is in response to your April 16, 2002 letter requesting a clarification of the phrase "no free liquid" as used in Special Provision 47 of § 172.102 of the Hazardous Materials Regulations (49 CFR Parts 171-180).
You stated your product is sealed inner packets, each containing a towelette absorbed with 6 ml of a Class 3, Packing Group II, insect repellent solution. You also stated when the packets are cut open on one end and inverted for 5 minutes, open side down, no liquid comes out. However, if shaken hard, one or two drops may come out of the packets.
The term "no free liquid" in Special Provision 47 describes the physical state when a liquid hazardous material is completely absorbed by a solid material such that no liquid is visible away from the solid material at the time the material is closed within the package. Therefore, your product is not subject to the regulations if, as you state, there is no free liquid in the packets.
I hope this information satisfies your inquiry.
Sincerely,
Hattie L. Mitchell
Chief, Regulatory Review and Reinvention
Office of Hazardous Materials Standards
172.102
Regulation Sections
| Section | Subject |
|---|---|
| 172.102 | Special provisions |