Interpretation Response #23-0010

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

Interpretation Response Details

Response Publish Date: 03/17/2023

Company Name: Advanced Printing Solutions

Individual Name: Bill Booth

Location State: OH Country: US

View the Interpretation Document

Response text:

March 17, 2023

Bill Booth
Advanced Printing Solutions
1201 Edison Drive
Cincinnati, OH  45216

Reference No. 23-0010

Dear Mr. Booth:

This letter is in response to your February 1, 2023, letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to limited quantities of "UN1210, Printing ink, flammable or Printing ink related material (including printing ink thinning or reducing compound), flammable, 3, PG II." Specifically, you are shipping "UN1210" in bottles—0.475 L each—that will be packaged in boxes containing four of the bottles, and three of these boxes will be consolidated in a larger outer box (for a total of 12 bottles per outer box). You seek confirmation that the printing ink can be shipped in this manner as a limited quantity via ground transportation provided the receptacles contain no more than one liter of "UN1210" per receptacle.

Section 173.150 of the HMR offers exceptions for the transport of limited quantities of Class 3 flammable liquids provided certain conditions are met, including exception from specification packaging requirements when packaged in combination packagings, according to § 173.150(b). For Class 3 packing group II material, inner packagings must not exceed 1 L (0.3 gallons) net capacity each, packed in a strong outer packaging, and the gross weight of the package must not exceed 30 kg (66 pounds).

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

173.150, 173.150(b)

Regulation Sections