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Interpretation Response #98-0275 ([Miller Products Company, Inc.] [Ms. Pat Czeczuga])

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

Interpretation Response Details

Response Publish Date:

Company Name: Miller Products Company, Inc.

Individual Name: Ms. Pat Czeczuga

Location State: NJ Country: US

View the Interpretation Document

Response text:

OCT 15, 1998


Ms. Pat Czeczuga                      Ref. No. 98-0275
Miller Products Company, Inc.
2220 91St Street
North Bergen,NJ 07047-4731

Dear Ms. Czeczuga:

This is in response to your letter dated September 10, 1998, requesting clarification on the limited quantity and consumer commodity provisions for Class 3 and Division 2.1 materials in §§ 173.150(b) (2) and 173.306(a) (3) of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask whether your packagings containing isopropyl alcohol may be shipped under these provisions.

Based on the information provided in your letter, you are correct in your understanding of the use of the limited quantity and consumer commodity exceptions for Class 3 materials in §.173.150(b) (2) and Division 2.1 materials in § 173.306(a) (3). Limited quantities of Class 3 materials and Division 2.1 materials are excepted from labeling requirements, unless offered for transportation by aircraft, placarding, and specification packaging.

In addition, a limited quantity of Class 3 or a Division 2.1 material which meets the definition of a consumer commodity in § 171.8, may be renamed consumer commodity and re-classed as ORM-D. An ORM-D material is also excepted from shipping paper requirements of the HMR unless it meets the definition of a hazardous substance, hazardous waste, or a marine pollutant, or is offered for transportation by aircraft.

I hope this satisfies your request.



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

173.150, 173.306

Regulation Sections

Section Subject
173.150 Exceptions for Class 3 (flammable and combustible liquids)
173.306 Limited quantities of compressed gases