Interpretation Response #02-0143 ([Gebauer Company] [Ron Coleman])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Gebauer Company
Individual Name: Ron Coleman
Location State: OH Country: US
View the Interpretation Document
Response text:
Sep 24, 202
Mr. Ron Coleman Reference No 02-0143
Gebauer Company
9410 St. Catherine Avenue
Cleveland, Ohio 44104
Dear Mr. Coleman:
This responds to your letter regarding aerosols packaged and offered for international transportation under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You state in your letter that under the International Civil Aviation Organization's Technical Instructions for the Safe Transport of Dangerous Goods by Air (ICAO Technical Instructions) the use of metal receptacles described as "IP.7, IP.7A, and IP.7B" are required for aerosols. You inquire whether your product, a non-hazardous medical solution, may be offered for transport internationally by air when packaged in DOT Specification 2Q aerosol containers and overpacked in non-UN standard outer packaging.
The answer is yes. Under the ICAO Technical Instructions, the use of an IP.7, IP.7A, or IP.7B receptacle is not required for an aerosol with a pressure below 970 kPa. Also, under the HMR, a specification aerosol container, such as a DOT 2P or 2Q, is not required for an aerosol with a pressure below 140 psig (965.3 kPa) at 130 °F (54 °C) but may be used. In addition, non-UN standard outer packaging meeting the general requirements of §§ 173.24 and 173.24a of the HMR would satisfy the requirements of the ICAO Technical Instructions under Packing Instruction Y203 (limited quantity) or Packing Instruction 910 (consumer commodity).
I trust this satisfies your inquiry. Please contact us if we can be of further assistance.
Sincerely,
Hattie L. Mitchell
Chief, Regulatory Review and Reinvention
Office of Hazardous Materials Standards
171.11