Interpretation Response #15-0153 ([Photosol, Inc. dba Photographic Solutions] [Mr. David Stone])

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

Interpretation Response Details

Response Publish Date: 04/15/2016

Company Name: Photosol, Inc. dba Photographic Solutions

Individual Name: Mr. David Stone

Location State: FL Country: US

View the Interpretation Document

Response text:

April 15, 2016

Mr. David M. Stone
President
Photosol, Inc. dba Photographic Solutions
430-G Ansin Blvd.
Hallandale, FL 33009

Ref No.: 15-0153

Dear Mr. Stone:

This letter is in response to your July 22, 2015 email requesting clarification to the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to a product your company produces and markets.  The specific product in question is a “wash n dry” style packet containing an absorbent synthetic cloth with approximately 3 drops (3mL) each of methanol, a Class 3 (flammable) liquid.  You state there is no free liquid present as it is completely absorbed by the material and fully sealed within the packet.

Under the HMR, your company’s product would be appropriately described as “UN3175, Solids containing flammable liquid, n.o.s., 4.1, PG II.”  However, as specified in
§ 172.102(c)(1), Special provision 47, small inner packagings consisting of sealed packets containing less than 10 mL of a Class 3 (flammable) liquid in Packing Group II or III, and absorbed into a solid material are not subject to the requirements of the HMR provided there is no free liquid in the packet.
 
I hope this information is helpful.  Please contact us if we can be of further assistance.

Sincerely,

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

172.102(c)(1)

Regulation Sections