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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #14-0141 ([Innovage, LLC] [Mr. Ron Van Bavel])

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

Interpretation Response Details

Response Publish Date:

Company Name: Innovage, LLC

Individual Name: Mr. Ron Van Bavel

Location State: CA Country: US

View the Interpretation Document

Response text:

Mr. Ron Van Bavel
Vice President
Innovage, LLC
19517 Pauling
Foothill Ranch, CA 92610

Ref. No.: 14-0141

Dear Mr. Bavel:

This is in response to your email dated July 15, 2014 requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) regarding transportation requirements for table tennis balls (ping pong balls). You note that your company is considering importing sets that contain four table tennis balls in each set. You state that the table tennis balls are made of celluloid. You ask if finished goods such as table tennis balls made of celluloid are a regulated commodity under the HMR.

In accordance with § 173.22, it is the shipper's responsibility to properly classify a hazardous material. This office generally does not perform this function. However, it is the opinion of this office that the entry for UN 2000 Celluloid only applies when the material is in a pre-manufactured state i.e. blocks, rod, rolls, sheets, tubes etc. PHMSA regulates the transportation in commerce of materials it determines are hazardous in that "the amount and form [of the material] may pose an unreasonable risk to health and safety or property." 49 U.S.C. 5103, as delegated to PHMSA in 49 CFR 1.53(b). Based on the information provided in your letter, including form and quantity of celluloid contained in the table tennis balls, it is our determination the table tennis balls are not in a quantity and form that pose an unreasonable risk to health, safety or property during transportation and, therefore, are not subject to regulation under the HMR.

I trust this information is helpful. If you have further questions, please do not hesitate to contact this office.



Shane C. Kelley
Acting International Standards Coordinator
Standards and Rulemaking Division

Regulation Sections

Section Subject
173.22 Shipper's responsibility