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Interpretation Response #99-0134 ([Sullivan and Guldin] [Mr. Dave Guldin])

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

Interpretation Response Details

Response Publish Date:

Company Name: Sullivan and Guldin

Individual Name: Mr. Dave Guldin

Location State: TN Country: US

View the Interpretation Document

Response text:

August 10, 1999


Mr. Dave Guldin                         Ref. No. 99-0134
Sullivan and Guldin
317 Iroquois Lane
Seymor, TN 37865

Dear Mr. Guldin:

This is in response to your letter dated May 12, 1999, concerning the requirements for classifying your product under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171­180).  Specifically, you ask if your product Alaskan Fire Mite' can be classified as a consumer commodity.

The answer to your question is no.  Based upon the information we have received, it appears that your product has the potential of being a self-ignition source.  If that is the case, your product is forbidden from transportation commerce based on the requirements of § 173.21.

To be of further assistance in classifying your product, we need additional specific information on how the device functions.  This includes specific information and test results on the ignition method and tests required by §§ 173.124 and 173.186(a).

If you have further questions, please do not hesitate to contact this Office.



Delmar F. Billings
Chief, Standards Development
Office of Hazardous Materials Standards


Regulation Sections

Section Subject
173.151 Exceptions for Class 4