Interpretation Response #98-0584 ([Amerex Corporation] [Mr. Fred B. Goodnight])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Amerex Corporation
Individual Name: Mr. Fred B. Goodnight
Location State: AL Country: US
View the Interpretation Document
Response text:
FEB 23, 1998
Mr. Fred B. Goodnight
Amerex Corporation
P.O. Box 81
Trussville, AL 35173-0081
Dear Mr. Goodnight:
This is in response to your letter of January 19, 1998, asking whether a fire extinguisher conforming to 49 CFR 173.309 may be shipped as a Consumer Commodity ORM-D in accordance with the provisions of § 173.144.
The answer is no. In order for a material to be reclassed as ORM-D, the material must: (1) meet the definition for consumer commodity in § 171.8; (2) be packaged for shipment in accordance with the limited quantity provisions; and (3) the packaging exception section, referenced in Column (8A) of the § 172.101 Hazardous Materials Table, must allow an exception for shipment as an ORM-D. In your case, the fire extinguishers may meet the definition of consumer commodity and may be packaged as a limited quantity, but § 173.309 does not authorize shipment of fire extinguishers as ORM-D.
I hope this information is helpful. Should you have further questions, do not hesitate to contact us.
Sincerely,
Delmer F. Billings
Chief, Standards Development
Office of Hazardous Materials Standards
Regulation Sections
| Section | Subject |
|---|---|
| 173.309 | Fire extinguishers |