Interpretation Response #02-0210 ([Phil Vonderwell])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name:
Individual Name: Phil Vonderwell
Location State: OH Country: US
View the Interpretation Document
Response text:
Oct 1, 2002
Mr. Phil Vonderwell Reference No.02-0210
Technical Consultant
RCS, Inc.-Ohio
950 Taylor Station Road, Suite M
Gahanna, Ohio 43230
Dear Mr. Vonderwell:
This is in response to your letter requesting clarification of the phrase "no free liquid" as used in Special Provision 47 of § 172.102 of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).
Your product consists of hermetically seated packets, each containing less than 10 mL of a Class 3, PG II, material absorbed onto a solid material. You stated that each packet contains a small amount of free liquid. It is your understanding that the term "no free liquid" means that all liquid has to be absorbed.
Your understanding is correct. The term "no free liquid" in Special Provision 47 describes the physical state when a liquid hazardous material is completely absorbed onto a solid material such that no liquid is visible away from the solid material at the time the material is closed within the package. Special Provision 47 applies only to the proper shipping name "Solids, containing flammable liquid, 4.1, UN3175, II." Because of the free liquid in the packets, that shipping name is inappropriate for your product; however, the packets may be shipped as a Class 3 material under the small quantity exception in § 173.4.
I trust this 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 |