USA Banner

Official US Government Icon

Official websites use .gov
A .gov website belongs to an official government organization in the United States.

Secure Site Icon

Secure .gov websites use HTTPS
A lock ( ) or https:// means you’ve safely connected to the .gov website. Share sensitive information only on official, secure websites.

U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #99-0198 ([HB Fuller Company] [Mr. Eugene J. Secor])

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

Interpretation Response Details

Response Publish Date:

Company Name: HB Fuller Company

Individual Name: Mr. Eugene J. Secor

Location State: MI Country: US

View the Interpretation Document

Response text:

September 8, 1999


Mr. Eugene J. Secor                    Ref.  No. 99-0198
HB Fuller Company
25200 Malvina Avenue
Warren, MI 48089

Dear Mr. Secor:

This is in response to your letter dated July 13, 1999, and subsequent telephone conversation with a member of my staff, regarding the small quantity exception in § 173.4 of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Specifically you ask if your one piece molded plastic device consisting of two separate reservoirs would be considered two separate inner receptacles.

Upon examination of your device it is the opinion of this Office that it is two separate receptacles that are attached.  Provided each receptacle contains less than the quantities specified in § 173.4 for inner receptacles, you may qualify for the small
quantity exception.

I hope this satisfies your request.



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


Regulation Sections

Section Subject
173.22 Shipper's responsibility