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Interpretation Response #98-0111 ([Department of Environmental Quality] [Mr. Daniel Schultz])

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

Interpretation Response Details

Response Publish Date:

Company Name: Department of Environmental Quality

Individual Name: Mr. Daniel Schultz

Location State: MI Country: US

View the Interpretation Document

Response text:

JUN 25, 1998


Mr. Daniel Schultz, Chief                  Ref. No.: 98-0111
Department of Environmental Quality
Field Operations Section
Environmental Response Division
Knapps Centre
PO Box 30426
Lansing, MI 48909-7926

Dear Mr. Schultz:

This is in response to your letter dated May 13, 1998, concerning the applicability of the small quantity exception in 49 CFR 173.4 to soil samples derived from a U.S. Environmental Protection Agency (EPA) sampling technique.  Specifically, you ask about EPA’s SW-846 Test Method 5035 which calls for the addition of 25 ml of methanol to a 25-gram soil sample and whether the methanol and soil mixture meets the small quantity exception.  You also ask if materials packaged under the small quantity exception have a 500 ml weight limitation.

The quantity limitations in § 173.4 are imposed upon the entire contents of each inner receptacle.  When classifying the material, the shipper must determine whether the material is a liquid or solid based on the definitions in § 171.8.  The 25 ml of liquid methanol added to 25 grams of soil is regulated as one material, not two separate materials.  The total quantity of the mixed materials per inner receptacle must not exceed 30 ml for a liquid or 30 grams for a solid.  Therefore, if the methanol and soil mixture still meets the definition of a hazardous material and is defined as a liquid, the total volume of material per inner receptacle must not exceed 30 ml to meet the small quantity exception.

Your second question concerns small quantity package weight limitations.  A completed small quantity package must not exceed 29 kg (§ 173.4(a)(8)).  However, the Hazardous Materials Regulations (49 CFR Parts 171-185) do not restrict the number of inner receptacles in a small quantity package.

I hope this satisfies your request.



John A. Gale
Transportation Regulations Specialist
Office of Hazardous Materials Standards

Berger and Schild:BAH:6/22/98


Regulation Sections

Section Subject
173.4 Small quantities for highway and rail