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Interpretation Response #11-0006 ([Stolt Tank Containers] [Mr. John Cario])

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

Interpretation Response Details

Response Publish Date:

Company Name: Stolt Tank Containers

Individual Name: Mr. John Cario

Location State: TX Country: US

View the Interpretation Document

Response text:

February 15, 2011




Mr. John Cario

Hazardous Materials Officer


Stolt Tank Containers

15635 Jacintoport Blvd

Houston, TX 77015

Ref. No. 11-0006

Dear Mr. Cario:

This responds to your January 3, 2011 request for clarification of the packing group determination for UN 3065, Alcoholic beverages under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask for confirmation that the packing group determination for alcoholic beverages is based on alcohol content and not flashpoint under both the HMR and the International Maritime Dangerous Good (IMDG) Code.

The answer to your question is yes. Alcoholic beverages are eligible for the exceptions in

§ 173.150(d) and (e) for Class 3 materials if they meet all the criteria, including the 24% or less alcohol content criteria. For materials with alcohol content above 24% by volume, the packing group is determined by Special Provision 24 as follows:

(1) Alcoholic beverages containing more than 24% but not more than 70% alcohol by volume are PG III; and

(2) Alcoholic beverages containing more than 70% alcohol by volume are PG II.

The HMR and the IMDG Code are consistent in their requirements for these materials.

I hope this answers your inquiry. If you need additional assistance, please contact this office at (202) 366-8553.


Ben Supko

Acting Chief, Standards Development

Standards and Rulemaking Division


Regulation Sections

Section Subject
172.101 Purpose and use of hazardous materials table
173.115 Class 2, Divisions 2.1, 2.2, and 2.3-Definitions