Interpretation Response #08-0056 ([Imperial Freight Brokers, Inc.] [Mr. Robert A. Becker])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Imperial Freight Brokers, Inc.
Individual Name: Mr. Robert A. Becker
Location State: FL Country: US
View the Interpretation Document
Response text:
May 16, 2008
Mr. Robert A. Becker
VP Global Sales
Imperial Freight Brokers, Inc.
2287 NW 102nd Place
Doral, FL 33172
Ref. No.: 08-0056
Dear Mr. Becker:
This is in response to your March 3, 2008 letter and subsequent conversation with a member of my staff requesting clarification on the shipment of alcohol pads under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You describe the product, "Alcohol Prep Pads," as pads saturated with less than 10 mL of 70% v/v isopropyl alcohol. The pads are individually packaged in a four-layer wrapper that provides an air-tight seal. Additionally, you ask if the HMR prohibit the transportation of these "Alcohol Prep Pads" with sharps, such as lancets, in the same freight container.
Alcohol pads or swabs are not subject to the HMR when they contain less than 10 mL of a Class 3 (flammable liquid) material in Packing Group II or III, including isopropyl alcohol or mixtures thereof, absorbed onto a solid material provided there is no free liquid in the packet or article. This determination is based on Special Provision 47 in § 172.102. The same exception is specified in Special Provision 216 of the International Maritime Dangerous Goods (IMDG) Code for the international transportation of dangerous goods by vessel. Neither the HMR nor the IMDG Code prohibit the transportation of alcohol pads and sharps, such as lancets, in the same freight container.
I hope this information is helpful. Please contact us if you require additional assistance.
Sincerely,
John A. Gale
Chief, Standards Development
Office of Hazardous Materials Standards
172.102 SP 47
Regulation Sections
| Section | Subject |
|---|---|
| 172.102 | Special provisions |