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Interpretation Response #06-0247 ([DelValCo Consultants] [Mr. George M. Thorpe])

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

Interpretation Response Details

Response Publish Date:

Company Name: DelValCo Consultants

Individual Name: Mr. George M. Thorpe

Location State: PA Country: US

View the Interpretation Document

Response text:

Jan 11, 2007


Mr. George M. Thorpe                Reference No. 06-0247
DelValCo Consultants
21 Ardmoor Lane
Chadds Ford, PA 19317

Dear Mr. Thorpe:

This responds to your letter regarding the shipment of Hydrogen peroxide, aqueous solution with more than 45 percent hydrogen peroxide by aircraft, in accordance with the small quantity exceptions in § 173.4 of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). The kit consists of two plastic syringes, each containing 1.19 ml (totaling 2.38 ml per kit) in an outer packaging (kits per shipping case with a maximum of four kits per case (totaling 9.52 ml per shipping case)).

Under the HMR, a material described as “Hydrogen peroxide, aqueous solution with more than 40 percent but not more than 60 percent hydrogen peroxide (stabilized as necessary), 5.1, UN2014, PG II” is forbidden for transportation by passenger and cargo- only aircraft (see in § 171.11(c) and the l72.101 Table, Columns 9A and 9B).

On March 22, 2006, [71 FR 14586; Docket HM-228} we published a final rule which revised the small quantity exceptions in § 173.4 and added a new Special Provision “A60” in § 172.102. Special Provision “A60” permits articles such as sterilization deuces, UN2014, Hydrogen peroxide, aqueous solutions with more than 40 percent but not more than 60 percent hydrogen peroxide (stabilized as necessary), when containing less than 30 ml per inner packaging with not more than 150 ml per outer packaging, to be transported in accordance with the provisions in § 173.4, irrespective of 173.4(a)(11)(i), provided such packagings were first subject to comparative fire testing. Comparative fire testing must show no difference in burning rate between a package as prepared for transport (including the substance to be transported) and an identical package : with water.

I hope this satisfies your inquiry. If we can be of further assistance, please contact us



John A. Gale
Chief, Standards Development
Office of Hazardous Materials Standards


Regulation Sections

Section Subject
173.4 Small quantities for highway and rail