Interpretation Response #07-0097 ([McGowan Enterprises, Inc.] [Mr. Jim Falls])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: McGowan Enterprises, Inc.
Individual Name: Mr. Jim Falls
Location State: CA Country: US
View the Interpretation Document
Response text:
Jun 27, 2007
Mr. Jim Falls Reference No. 07-0097
McGowan Enterprises, Inc.
12225 World Trade Drive, Suite F
San Diego, CA 92128
Dear Mr. Falls:
This is in response to your May 3, 2007 letter regarding the transportation of isopropanol under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if 70 percent isopropanol may be transported via air or highway transportation. In your letter you state that the 70 percent isopropanol is packaged in a combination packaging consisting of four one-gallon inner receptacles and in pre-saturated wipes.
Provided your packaging meets the applicable requirements in Parts 173 and 178, the 70 percent isopropanol (as described in your letter) may be transported by any mode of transportation; however, there are restrictions concerning passenger aircraft and passenger rail transportation. Your combination packaging contains more than five liters of isopropanol per packaging (i.e., it contains 15.14 liters). As specified in Column 9A of the Hazardous Materials Table ( 172.101 HMT), the 70 percent isopropanol may not be offered for transportation in packages exceeding five liters net quantity when intended for passenger aircraft or passenger rail. Therefore, your combination packagings, as described, may not be transported by passenger aircraft or passenger rail.
Wipes containing isopropanol are most appropriately transported under the proper shipping name “Solids containing flammable liquids, n.o.s.” 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.
I hope this information is helpful. If you have further questions, please do not hesitate to contact this office.
Sincerely,
Hattie L. Mitchell
Chief, Regulatory Review and Reinvention
Office of Hazardous Materials Standards
172.101
Regulation Sections
| Section | Subject |
|---|---|
| 172.101 | Purpose and use of hazardous materials table |