Interpretation Response #23-0063
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Hazmat Safety Consulting, LLC
Individual Name: Mr. Robert Richard
Location State: VA Country: US
View the Interpretation Document
Response text:
October 30, 2023
Mr. Robert Richard
President
Hazmat Safety Consulting, LLC
10036 Lake Occoquan Drive
Manassas, VA 20111
Reference No. 23-0063
Dear Mr. Richard:
This letter is in response to your July 11, 2023, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the packaging requirements for pyrophoric liquid materials as found in § 173.181(c). You state that the term "metal cans" is not clearly defined in paragraph (c), and that your client uses "tight metal receptacles"—which you describe as non-specification cylinders—to meet this packaging requirement. Specifically, you ask whether such packagings satisfy the requirements of this packaging instruction for pyrophoric liquid materials.
It is the opinion of this Office that a non-specification metal cylinder could be a type of metal can or receptacle. In accordance with § 173.181(c), each inner metal receptacle must be strong, tight, closed by positive means rather than friction, and not over 4.0 L (1 gallon) capacity.
I hope this information is helpful. Please contact us if we can be of further assistance.
Sincerely,
T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division
173.181(c)
Regulation Sections
| Section | Subject |
|---|---|
| 173.181 | Pyrophoric materials (liquids) |