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Interpretation Response #98-0366 ([Aero Tech Consumer Aerospace] [Mr. Gary C. Rosenfield])

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

Interpretation Response Details

Response Publish Date:

Company Name: Aero Tech Consumer Aerospace

Individual Name: Mr. Gary C. Rosenfield

Location State: NV Country: US

View the Interpretation Document

Response text:

May 13,1999


Mr. Gary C. Rosenfield                          Ref.. No.98-0366
Aero Tech Consumer Aerospace
1955 South Palm Street, Suite 15
Las Vegas, Nevada 89104

Dear Mr. Rosenfield:

This is in response to your letter dated November 25,1998, requesting clarification on the applicability of the hazardous Materials Regulations (HMR:49 CFR Parts 171-180) to your liquid slurry mixture and  requirements for placarding vehicle carrying Division 1.3 material.

Under 49 CFR 173.22, it is the shipper's responsibility to properly classify a hazardous material. Based on the information you provided, we are not able to determine the proper classification. We recommend that you evaluate and test your mixture to determine if it meets the hazard class defining criteria in Part 173. We want to emphasize that if this composition is intended to produce an explosive or pyrotechnic effect, it must be evaluate under the provisions in 173.56.

In reference to your question on placarding, a manufacturer carrying Division 1.3 materials in its own or rented vehicles in local or intrastate transportation, must placard the transport vehicle in accordance with 49 CFR 172.504. Effective October 1, 1998, the HMR now apply to both intrastate and intrastate transportation of hazardous materials in commerce.

I hope this answers Your inquiry.



Delmer F. Billings
Chief, Standards Development
Office of Hazardous Materials Standards


Regulation Sections

Section Subject
173.22 Shipper's responsibility