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Interpretation Response #12-0029 ([Colorcon No Tox Products] [Mr. Tim Jamison])

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

Interpretation Response Details

Response Publish Date:

Company Name: Colorcon No Tox Products

Individual Name: Mr. Tim Jamison

Location State: PA Country: US

View the Interpretation Document

Response text:

March 29, 2012



Mr. Tim Jamison
Logistics Manager
Colorcon No Tox Products
171 New Britain Blvd.
Chalfont, PA 18914

Ref. No. 12-0029

Dear Mr. Jamison:

This responds to your January 23, 2012, request for clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). According to your letter your product contains 24% or less alcohol by volume and contains no less than 50% water, as well as less than 3% of ammonium hydroxide solution as a PH balancer. You ask whether your product meets the provisions of the § 173.150(e) exception for aqueous solutions.

The answer is no. It is the opinion of this office that the product you describe does not qualify for the § 173.150(e) exception for aqueous solutions because it contains other hazardous material, i.e. ammonium hydroxide. The aqueous solution may not contain any other hazardous material as defined in § 171.8. Section 173.150(e) authorizes an aqueous solution containing 24% or less alcohol by volume and no other hazardous material to be either reclassed as a combustible liquid or excepted from regulation under the HMR if it contains 50% or more water.

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 Branch
Standards and Rulemaking Division

173.150, 171.8

Regulation Sections

Section Subject
171.8 Definitions and abbreviations
173.150 Exceptions for Class 3 (flammable and combustible liquids)