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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 #15-0192 ([Mr. David Gobaud])

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

Interpretation Response Details

Response Publish Date:

Company Name:

Individual Name: Mr. David Gobaud

Location State: CA Country: US

View the Interpretation Document

Response text:

December 14, 2015

Mr. David Gobaud
1270 Ortiz Ct.
Sunnyvale, CA 94089

Ref. No.: 15-0192

Dear Mr. Gobaud:

This responds to your September 17, 2015 email request for clarification of the definition of a consumer commodity under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask whether gasoline in a 110 gallon aluminum tank authorized by DOT SP 14227 meets the definition of consumer commodity. In your letter you note that gasoline meets the definition of a consumer commodity as defined by the HMR in § 171.8.
Gasoline transported in a 110 gallon tank would not meet the quantity limits specified for a limited quantity or a consumer commodity. To be shipped as a consumer commodity, the gasoline must be packaged in accordance with the limited quantity provisions in § 173.150. Gasoline is a flammable liquid of packing group II. As such, a limited quantity of gasoline is limited to 1L (0.3 gallons) per inner packaging. The inner packaging must be packed in a strong outer packaging and the completed package may not exceed 30 kg (66 lbs) gross weight (see § 173.150(b)).  The package described in your letter exceeds the quantity limits for limited quantities and consumer commodities as described in § 173.150(b).
I hope this answers your inquiry.  If you need additional assistance, please contact the Standards and Rulemaking Division at (202) 366-8553.

Sincerely,

Ben Supko
Senior Regulations Officer
Standards and Rulemaking Division

171.8, 173.150, 173.150(b)

Regulation Sections

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