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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 #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.


Dirk Der Kinderen
Chief, Standards Development Branch
Standards and Rulemaking Division

171.8, 173.150(e)

Regulation Sections

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