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Interpretation Response #99-0047 ([Texas Woman's University] [Charles L. Riggs, Ph.D.])

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

Interpretation Response Details

Response Publish Date:

Company Name: Texas Woman's University

Individual Name: Charles L. Riggs, Ph.D.

Location State: TX Country: US

View the Interpretation Document

Response text:

August 7, 1999


Charles L. Riggs, Ph.D.                             Ref No. 99-0047
Texas Woman's University
College of Arts and Sciences
P.O. Box 425529
Denton, TX 76204-5529

Dear Dr. Riggs:

This is in response to your letter regarding requirements for shipping chemical test kits with small quantities of dilute chemicals in accordance with the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  You enclosed Exhibits "A" and "B." I apologize for the delay in responding and hope
it has not caused any inconvenience.

You stated that the chemical test kits are sold by Textile Rental Services Association of America (TRSA).  Texas Woman's University (TWU) is interested in assuming the responsibility for the production of these test kits for TRSA.  The layout and content of each test kit is presented in Exhibit "A".  Exhibit "B" contains copies of previous correspondence between Mr. J.C. Sherrill of Sherrill Associates, and the U.S. Department of Transportation (DOT), written in 1985 and 1986, requesting to become party to the exemption DOT-E 6762.  You asked for confirmation  that the exemption is no longer necessary, and whether the TRSA "Washroom Test Kit" containing certain corrosive and flammable chemicals are considered hazardous materials for purposes of transportation in commerce.

It is the shipper's responsibility to properly classify a hazardous material in accordance with the hazard class definitions in Part 173 of the HMR.  This Office does not perform that function (See 49 CFR 173.22). We do not agree with your previous determination that certain chemicals in your test kit, i.e., sulfuric acid, hydrochloric acid, and sodium hydroxide are "non-hazardous."

Under the HMR, Chemical kits containing small amounts of various compatible hazardous materials which are used for medical, analytical, or testing purposes must be prepared and shipped in accordance with Special Provision "15" in 49 CFR 172.102. For "Chemical kits", the quantity of hazardous materials in an inner packaging must not exceed 250 ml for liquids or 250 g for solids, and must be protected from other materials in the kit.  The total quantity or gross weight of hazardous material in any one kit must not exceed 1 L or 1 kg.  The total quantity of hazardous material in any one package must not exceed 10 L or 10 kg.  For transportation aboard aircraft, the package of hazardous material may not exceed the quantity limitations prescribed for the material in Column 9A or 9B of the 49 CFR
172.101 Table (See 49 CFR 173.27).

The exemption DOT-E 6762, which authorized certain corrosive and flammable liquids and ORM-A and ORM-B materials to be transported as "Chemical Kits" in non-specification, plastic packagings overpacked in fiberboard outside packagings, was not renewable beyond September 30, 1996.  Therefore, exemption DOT-E-6762 is no longer valid or necessary.

I hope this satisfies your inquiry.  If we can be of further assistance, please contact us.



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


Regulation Sections

Section Subject
173.22 Shipper's responsibility