{"operation":"document","citation":"00-0075","title":"Innowave Incorporated — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2000-03-30","effective_on":null,"summary":"00-0075 response to Innowave Incorporated concerning 173.22.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-00-0075.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-00-0075.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-00-0075","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2000/000075.pdf","body":"<<<PAGE 1>>>\n\nf Transportatio\nS. Departmen\n400 Seventh Street, S.W.\nWashington, D.C.\nResearch and\n20590\nSpecial Programs\nAdministration\nMAR 3 0 2000\nMr. Robert Haney\nInnowave Incorporated\nRef. No. 00-0075\n3201 Farnam Street\nOmaha, Nebraska 68131\nDear Mr. Haney:\nThis is in response to your letter dated March 1, 2000, and subsequent telephone conversation with\nEric Nelson of our staff regarding the proper hazard class or division for your products, FreshCUP\nBioCleansing Solutions, under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).\nBased on subsequent information sent to this Office and additional telephone conversations with\nMr. Nelson, this Office can not determine the hazard class or division for your products. However, it is\npossible that these products may meet the definition of a corrosive liquid, and therefore subject to the\nHMR. We understand that these products are to be imported into the United States from Israel.\nUnder § 173.22 of the HMR, it is the shipper's responsibility to properly class a hazardous material,\nand it may be necessary to test these products to determine their proper hazard class or division. As\nprovided by § 171.12, it is the importer's responsibility to furnish to the shipper and forwarding agent at\nthe place of entry into the United States, complete information as to the requirements of the HMR. In\naddition to the requirements of the HMR, international air and vessel shipments of hazardous materials\nare subject to the provisions of the International Civil Aviation Organization's Technical Instructions\nand/or the International Maritime Dangerous Goods Code.\nI hope this satisfies your request.\nSincerely,\nDelmer F. Billings\nChief, Standards Development\nOffice of Hazardous Materials Standards\n000075\n173,22\n\n<<<PAGE 2>>>\n\n* o The Highest Standards...\nThe Safest Drinking Water\ninnowave®\nA MUTUAL OF OMAHA SUBSIDIARY\nnelson\nMarch 1, 2000\n$173.22\n00-0075\nOffice of Hazardous Materials Standards,\nMs. Gail P. Mayhew\nU.S.Department of Transportation\nResearch & Special Programs Administration\n400 Seventh Street, S.W.\nRoom 8407\nWashington, D.C. 20590\nRE: FreshCUP Project - Biocleansing Solution\nDear Ms. Mayhew:\nmaha. We are a subsidiary of the Mutual ef Omaha Insurance Companies. We are hoping that you ca\nBy way of introduction, innowave incorporated is a water purification company based out of\nsint usael calied the fresh ofthe regulatory issues associated with a new product we are going to impor\nfor that solution. We are trying to make sure there are no DOT regulations that we have overlooked\nThe FreshCUP utilizes a BioCleansing Solution, and I am enclosing a copy of the MSDS sheets\nand want to make sure there are no outstanding regulatory concerns.\nconcerning the transport of the soap solution. We eventually plan to sell this product in all of the 50 states\nspecial permits, procedures, labels, etc. required for the transport of the FreshCUP detergent. If we do not\nWe wouid very much appreciate a written statement from your office as to whether there are any\nhear back from your office by April I, 2000, we will assume that we have met all of the applicatle\nstandards.\nhesitate to contact me should you have any questions.\nThanks for your help. I look forward to receiving your response. In the meantime, please don't\nVery truly yours,\nBat tang\nBob Haney\nProduct Manager\nEnclosure\nEthirt. Hanry E\nmutrilotomcha.com\n351\nwww.innowave.com","truncated":false,"body_characters":3424}