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Interpretation Response #09-0070 ([Thermo Fisher Scientific] [Mr. Gene Sanders])

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

Interpretation Response Details

Response Publish Date:

Company Name: Thermo Fisher Scientific

Individual Name: Mr. Gene Sanders

Location State: PA Country: US

View the Interpretation Document

Response text:

August 26, 2009



Mr. Gene Sanders

Thermo Fisher Scientific

2000 Park Lane

Pittsburgh, PA 15275

Ref. No. 09-0070

Dear Mr. Sanders:

This responds to your e-mail requesting confirmation that your company"s High Pressure Liquid Chromatography (HPLC) column is not regulated under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). According to your e-mail, the HPLC columns are constructed of steel tubing and filled with inert packing material that is wetted with a flammable liquid. The columns contain no free-flowing liquid and the ends are sealed with caps or plugs.

Based on the information provided in your e-mail, it is the opinion of this Office that your company"s HPLC columns are in a quantity and form that do not pose a risk in transportation. Therefore, the HPLC columns are not regulated under the HMR.

I trust this satisfies your inquiry. Please contact us if we can be of further assistance.


Hattie L. Mitchell

Chief, Regulatory Review and Reinvention

Office of Hazardous Materials Standards


Regulation Sections

Section Subject
171.1 Applicability of Hazardous Materials Regulations (HMR) to persons and functions
172.101 Purpose and use of hazardous materials table