Interpretation Response #20-0082
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: Lawrence Bierlein
Location State: MD Country: US
View the Interpretation Document
Response text:
February 10, 2021
Lawrence Bierlein
[Address Line 1]
[Address Line 2 (if applicable)]
[City, State Abbreviation Zip]
Reference No. 20-0082
Dear Mr. Bierlein:
This letter is in response to your October 13, 2020, email and subsequent discussions with my staff requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the aqueous solution of alcohol exception in § 173.150(e). On behalf of your client, you ask whether a personal care gel composed of 64% water, 20% isopropyl alcohol, 1.2% ammonia solution, and several other non-hazardous components is eligible to be transported in accordance with the exception for aqueous solutions of alcohol in § 173.150(e). You state your understanding that the gel in question is not subject to the HMR in accordance with § 173.150(e).
The answer is yes. If the ammonia solution component, in the concentration present in the gel, does not meet the definition of "hazardous material" in § 171.8, then the presence of the ammonia solution component does not preclude the gel from eligibility for the exception in § 173.150(e).
I hope this information is helpful. Please contact us if we can be of further assistance.
Sincerely,
Dirk Der Kinderen
Chief, Standards Development Branch
Standards and Rulemaking Division
171.8, 173.150(e)