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Interpretation Response #98-0398 ([H.B. Fuller Automotive Company] [Mr. Gene Secor])

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

Interpretation Response Details

Response Publish Date:

Company Name: H.B. Fuller Automotive Company

Individual Name: Mr. Gene Secor

Location State: MI Country: US

View the Interpretation Document

Response text:

APR 15, 1998


Mr. Gene Secor
Environmental Health and Safety Department
H.B. Fuller Automotive Company
31601 Research Park Drive
Madison Heights, MI 48071

Dear Mr. Secor:

This is in response to your letters and telephone conversations with members of my staff and the Office of Hazardous Materials Technology asking if an adhesive with the proper shipping description "Self heating, solid" organic, n.o.s., 4.2, UN 3088," formulated as either PG II or
PG ill, is subject to the requirements specified in the Hazardous Materials Regulations (49 CFR Parts 171-180) when placed between automotive parts and offered for transportation on racks with no outside packaging. You stated the adhesive is applied to provide structural support to the parts before they are cured.

You provided the following additional information:

  1. the parts are large metal assemblies such as rear tailgates, doors, hood decks, and fenders used predominantly on mini vans and small utility vehicles.
  2. a maximum amount of2.6 ounces of the adhesive is placed around the outer periphery of the parts in a 16-foot long continuous bead that is 3 mm wide and high, and the parts are sandwiched together.
  3. the parts are cured in an oven at 30QOF to 350°F.
  4. the maximum temperature developed on the surface ofthe parts when they are cured is 300°F to 350OP.

The answer is no, the adhesive no longer meets the definition of a Division 4.2 material in the packaging and transportation scenario described. Thank you for your inquiry. Ifwe can assist you further, please contact us.



Hattie L. Mitchell, Chief
Regulatory Review and Reinvention
Office of Hazardous Materials Standards


Regulation Sections

Section Subject
172.101 Purpose and use of hazardous materials table