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Interpretation Response #99-0116 ([Stored Energy Concepts, Inc.] [Mr. Richard E. Lisowski])

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

Interpretation Response Details

Response Publish Date:

Company Name: Stored Energy Concepts, Inc.

Individual Name: Mr. Richard E. Lisowski

Location State: PA Country: US

View the Interpretation Document

Response text:

AUG 12, 1999


Mr. Richard E. Lisowski                    Ref. No. 99-0116
Stored Energy Concepts, Inc.
P.O. Box 387
St. Peters, PA 19470-0387

Dear Mr. Lisowski:

This is in response to your letter dated May 3, 1999 and telephone conversation with a member of my staff, regarding small quantity exceptions under the Hazardous  Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically you ask if your device classified as “Life-saving appliances,-.not self-inflating, Class 9, UN3072" may be shipped under the small.quantity exception in § 173.4.

The answer is no.  The 30 gram quantity limitation in 173.4 (a) (1) (ii) applies to the life saving appliance, not just the explosive component.  Your life saving appliance, which was classified under an approval (EX9707049.) as-a Class 9, weighs more than 30 grams.  The life saving. appliance may only be shipped under the small quantity exception if the entire device meets the quantity limitations of 30 grams in § 173.4(a) (1) (ii).

I hope this satisfies your request.



John A. Gale   
Transportation Regulations Specialist
Office of Hazardous Materials Standards


Regulation Sections

Section Subject
173.4 Small quantities for highway and rail