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Interpretation Response #04-0176 ([Shipmate, Inc.] [Mr. Robert Tieman])

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

Interpretation Response Details

Response Publish Date:

Company Name: Shipmate, Inc.

Individual Name: Mr. Robert Tieman

Location State: CA Country: US

View the Interpretation Document

Response text:

Sep 29, 2004


Mr. Robert Tieman                 Reference No. 04-0176
Shipmate, Inc.
18436 Hawthorne Blvd, Suite 201
Torrance, CA 90504

Dear Mr. Tieman:

This is in response to your July 26, 2004 letter regarding the applicability of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) to Firestarters TM lighter cubes. You state that your products contain no more than 10 ml of “fuel” and there is no free liquid in the cells.

For the proper shipping name “Solids containing flammable liquids, n.o.s.,” the Hazardous Materials Table refers you to special provision 47. Special provision 47 excepts from the HMR sealed packets that contain less than 10 ml of a flammable liquid in Packing Group II or III when the liquid is completely absorbed onto a solid material. Based on the information that you provided in your letter, it is the opinion of this Office that your Firestarters TM lighter cubes are not subject to the requirements of the HMR.

I hope this information is helpful.



Hattie L. Mitchell
Chief, Regulatory Review and Reinvention
Office of Hazardous Materials Standards


Regulation Sections

Section Subject
173.22 Shipper's responsibility