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Interpretation Response #05-0222 ([Gas Industries LLC] [Mr. John E. Brooks])

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

Interpretation Response Details

Response Publish Date:

Company Name: Gas Industries LLC

Individual Name: Mr. John E. Brooks

Location State: WA Country: US

View the Interpretation Document

Response text:

Nov 17, 2005


Mr. John E. Brooks                      Reference No. 05-0222
FirePak Oil and
Gas Industries LLC
164 NW Jib Street
Oak Harbor, WA 98277

Dear Mr. Brooks:

This is in response to your August 10, 2005 letter regarding the applicability of the consumer commodity provisions as specified in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) - Specifically, you ask if your fire suppression system described as “Flammable solids, organic, n.o.s., Division 4.1, UN 1325, PG III” qualifies for the consumer commodity exception in § 173.151(c).

The answer is no. Upon further review of the information provided, we have determined that this material is an “explosive device” and needs to be approved by the Associate Administrator under the terms specified in § 173.56.

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



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


Regulation Sections

Section Subject
173.151 Exceptions for Class 4