Interpretation Response #07-0191 ([Zippo Manufacturing] [Mr. David H. Baker])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Zippo Manufacturing
Individual Name: Mr. David H. Baker
Location State: DC Country: US
View the Interpretation Document
Response text:
Nov 19, 2007
Mr. David H. Baker
Attorney for Zippo Manufacturing
Law Offices of David H. Baker LLC
1700 Pennsylvania Avenue, N.W.,
Suite 400
Washington, D.C. 20006
Ref. No. 07-0191
Dear Mr. Baker:
This responds to your letter regarding the applicability of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) to your client, Zippo Manufacturing Company ("Zippo"). Specifically, you ask for confirmation from this office that the "purging" method Zippo is suggesting to its customers for its liquid-fueled, non-pressurized lighters conforms to the requirements in § 172.102, Special Provision 168 of the HMR. You submitted test report results with your request showing that if the lighter is disassembled and the fuel allowed to evaporate for at least 24 hours, the lighter will no longer ignite and only trace (negligible) amounts of fuel remain.
Section 172.102, Special Provision 168, states a lighter that is cleaned and purged of vapors is not subject to the HMR. While this office generally does not endorse a specific method to accomplish this provision, we agree that your suggested test method appears to satisfy this provision. Thus, lighters conforming to this method would not be subject to the HMR.
I trust this satisfies your request. Please contact us if we can be of further assistance.
Sincerely,
Hattie L. Mitchell
Chief, Regulatory Review and Reinvention
Office of Hazardous Materials Standards
172.102, Special Provision 168
Regulation Sections
| Section | Subject |
|---|---|
| 172.102 | Special provisions |