USA Banner

Official US Government Icon

Official websites use .gov
A .gov website belongs to an official government organization in the United States.

Secure Site Icon

Secure .gov websites use HTTPS
A lock ( ) or https:// means you’ve safely connected to the .gov website. Share sensitive information only on official, secure websites.

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.


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)