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Interpretation Response #07-0020 ([Applied Biosystems] [Ms. Connie Roxas])

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

Interpretation Response Details

Response Publish Date:

Company Name: Applied Biosystems

Individual Name: Ms. Connie Roxas

Location State: DC Country: US

View the Interpretation Document

Response text:

Feb 28, 2007

Ms. Connie Roxas                                         
Reference No. 07-0020
Quality and Regulatory Compliance
Applied Biosystems
850 Lincoln Centre Drive
Foster City, CA 94404-1128

Dear Ms. Roxas:

This responds to your February 1, 2007 letter requesting clarification on proper shipping descriptions under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if two aqueous solutions of alcohol described in your letter are eligible for the exception in § 173.150(e).

In accordance with § 173.150(e), aqueous solutions of alcohol containing 24% or less alcohol by volume and no other hazardous materials: (1) may be reclassed as a combustible liquid; and (2) are not subject to the requirements of the HMR if they contain no less than 50% water. According to your letter, both of your solutions of alcohol contain less than 24% alcohol by volume, no other hazardous material, and also contain more than 50% water. Based on the information provided in your letter, it is the opinion of this Office that the two aqueous solutions of alcohol described in your letter are not subject to the requirements of the HMR.

I hope this answers your inquiry.


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

172.101, 173.150 (e)

Regulation Sections

Section Subject
172.101 Purpose and use of hazardous materials table
173.150 Exceptions for Class 3 (flammable and combustible liquids)