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Interpretation Response #11-0142 ([Patterson Companies, Inc.] [Mr. Robb Boros])

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

Interpretation Response Details

Response Publish Date:

Company Name: Patterson Companies, Inc.

Individual Name: Mr. Robb Boros

Location State: IA Country: US

View the Interpretation Document

Response text:

January 5, 2012



Mr. Robb Boros
Compliance Coordinator
Patterson Companies, Inc.
Patterson Logistics Services, Inc.
1905 Lakewood Drive
Boone, Iowa 50036

Ref. No. 11-0142

Dear Mr. Boros:

This is in response to your letter, and subsequent conversation with a member of my staff, requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to a suture product and needle packaged in a hermetically-sealed foiled pouch containing between 1.2 mL and 1.5 mL of an isopropanol-based wetting agent with a flashpoint of 12 ºC. In your letter, you state that upon opening a sample of your client"s foil pouch, free liquid was visibly present. You ask whether the proper shipping name "Solids containing flammable liquids, n.o.s." is appropriate, and, is therefore subject to the HMR.

Based on the scenario described in your letter, the answer is no, you may not use the proper shipping name "Solids containing flammable liquids, n.o.s." Further, it is the opinion of this Office that your client"s product is fully subject to the requirements of the HMR and another description must be selected appropriate to the packaged substance. The proper shipping name "Solids containing flammable liquids, n.o.s.," in the § 172.101 Hazardous Materials Table refers the reader to § 172.102(c)(1) Special provision 47. 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. Although your client"s product contains less than 10 mL of a flammable liquid, the liquid is not completely absorbed onto a solid material and free liquid is visible.

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


T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division


172.102 SP 47, 172.101

Regulation Sections

Section Subject
172.101 Purpose and use of hazardous materials table