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Interpretation Response #99-0120 ([Chemtronics] [Mr. Bill Dowse])

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

Interpretation Response Details

Response Publish Date:

Company Name: Chemtronics

Individual Name: Mr. Bill Dowse

Location State: GA Country: US

View the Interpretation Document

Response text:

JUL 1, 1999

Mr. Bill Dowse                              Ref.  No. 99-0120
Distribution Manager
8125 Cobb Center
Kennesaw, GA 30152

Dear Mr. Dowse:

This is in response to your letter concerning the consumer commodity exceptions under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171- 180). Your company is planning to ship Difluoroethane, R 152a, 2.1, UN1030 in aerosol containers under DOT exemption E-11516.

Your material must meet the definition of consumer commodity in § 171.8 and the limited quantity provisions of § 173.306 in order to be renamed and reclassed as "Consumer Commodity, ORM-D." For a pure flammable gas, you would be required to meet the  provisions in § 173.306(a)(1), which requires your material to be in a container of not more that 4 fluid ounces capacity (7.22 cubic inches or less).  If you plan on .shipping containers which exceed the 4 fluid ounce capacity limit, your material will not be eligible for the consumer commodity exception.

I hope this satisfies your request.



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


Regulation Sections

Section Subject
173.306 Limited quantities of compressed gases