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Interpretation Response #13-0161 ([Royal Oak Enterprises LLC] [Mr. Phillip Zimmerman])

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

Interpretation Response Details

Response Publish Date:

Company Name: Royal Oak Enterprises LLC

Individual Name: Mr. Phillip Zimmerman

Location State: GA Country: US

View the Interpretation Document

Response text:

September 6, 2013

Mr. Phillip Zimmerman
Royal Oak Enterprises LLC
One Royal Oak Ave.
Roswell, GA 30076

Ref No.: 13-0161

Dear Mr. Zimmerman:

This is a response to your July 31, 2013 email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) with regard to the classification of Division 4.2 (spontaneously combustible) materials.  Specifically, you seek clarification on whether charcoal briquettes you produce meet the definition of a Division 4.2 (spontaneously combustible) material per § 173.124(b)(2) of the HMR.  In your email, you provide data on the testing of self-heating substances for three of your products.  

In accordance with § 173.124(b)(2), a self-heating material is a material that through a process where the gradual reaction of that substance with oxygen (in air) generates heat.  If the rate of heat production exceeds the rate of heat loss, then the temperature of the substance will rise which, after an induction time, may lead to self-ignition and combustion.  A material of this type which exhibits spontaneous ignition or if the temperature of the sample exceeds 200 °C (392 °F) during the 24-hour test period, when tested in accordance with UN Manual of Tests and Criteria, is classified as a Division 4.2 hazardous material.

In accordance with § 173.22, it is the shipper's responsibility to properly classify a hazardous material.  This Office does not generally perform that function.  However, based on the data you provided, the three charcoal briquette products do not meet the definition of a Division 4.2 (spontaneously combustible) material.  

I hope this information is helpful.  If you have any more questions, please do not hesitate to contact this office.


Robert Benedict
Chief, Standards Development
Standards and Rulemaking Division

173.124(b)(2), 173.22

Regulation Sections

Section Subject
173.124 Class 4, Divisions 4.1, 4.2 and 4.3-Definitions
173.22 Shipper's responsibility