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Interpretation Response #02-0219 ([Mountain Safety Research] [Joe Yelverton])

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

Interpretation Response Details

Response Publish Date:

Company Name: Mountain Safety Research

Individual Name: Joe Yelverton

Location State: WA Country: US

View the Interpretation Document

Response text:

Oct 16, 2002

Mr. Joe Yelverton                 Reference No. 02-0219
Mountain Safety Research
3800 First Avenue South
Seattle, WA 98134

Dear Mr. Yelverton:

This is in response to your August 16, 2002, letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Specifically, you request confirmation that your product meets the limited quantity provisions in § 173.306 (a) (1). You also asked whether your product may be renamed "Consumer Commodity" and reclassed as "ORM-D" material.

You describe your product as a 4 ounce capacity can containing liquefied petroleum gas (LPG).  You also state that your product is intended to be sold to consumers for personal consumption and, therefore, meets the definition of a "Consumer Commodity" as defined in § 171.8.

Your understanding is correct. Your product consisting of a mixture of liquefied compressed gases in a container of not more than four (4) fluid ounces capacity, meets the definition for a limited quantity under § 173.306 (a) (1) of the HMR and is, therefore, excepted from the specification packaging requirements and labeling requirements except when offered for transportation by air.  Further, the provisions in § 173.306 specify that a limited quantity which conforms to § 173.306 (a) (1) and meets the definition of consumer commodity may be renamed "Consumer Commodity" and reclassed as "ORM-D" material.

I hope this information is helpful.  If you have further questions, please do not hesitate to contact this office.


Delmer Billings
Chief, Standards Development
Office of Hazardous Materials Standards


Regulation Sections

Section Subject
173.306 Limited quantities of compressed gases