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Interpretation Response #12-0174 ([Process Technology Optimization, Inc.] [Dr. Tilak Bommaraju])

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

Interpretation Response Details

Response Publish Date:

Company Name: Process Technology Optimization, Inc.

Individual Name: Dr. Tilak Bommaraju

Location State: NY Country: US

View the Interpretation Document

Response text:

October 3, 2012


Dr. Tilak Bommaraju
Vice President
Process Technology Optimization, Inc.
2801 Long Road
Grand Island, NY 14072

Reference No.: 12-0174

Dear Dr. Bommaraju:

This is in response to your July 31, 2012 letter requesting confirmation that two new formulations for Flameless Ration Heaters (FRHs) developed by your company for use by the U.S. Department of Defense are not subject to the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).

As provided in § 173.22, it is the shipper's responsibility to properly classify a hazardous material. Such determinations are not required to be verified by this office. However, based on the Material Safety Data Sheet (MSDS) and test results you provided for each formulation, it is the opinion of this office that the described FRH formulations do not meet the definition of a Division 4.1, Division 4.3, Division 5.1, or Division 6.1 material and, provided they do not meet the criteria for any other hazard class, neither formulation is subject to the HMR.

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



Delmer Billings
Senior Regulatory Advisor
Standards and Rulemaking Division


Regulation Sections

Section Subject
173.22 Shipper's responsibility