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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