Guidanceguidance
00-0196
Tandem Technologies International — Hazardous Materials Safety Interpretation
Current as of source date Government source
RegulusPipeline researchRegulusPipeline research00-0196
Page 1U.S. Department 400 Seventh St., S.W. of Transportation Washington, D.C. 20590 Special Programs Research and Administration AUG 1 5 2000 Mr. R. Jett Rich Ref. No. 00-0196 Tandem Technologies International 108 Columbia Way Carrollton, GA 30117-2024 Dear Mr. Rich: This is in response to your letter dated July 10, 2000 regarding the transportation of a combustible liquid under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) . Specifically, you ask if a liquid that meets the definition of a combustible liquid under § 173.120(b) is subject to the HMR when transported in a non-bulk packaging. The answer is no. As provided by § 173.120 (b) (1), a point above 60.5°C (141°F) and below 93°C (200°F) and that combustible liquid is defined as a material that has a flash does not meet the definition of any other hazard class under the HMR. A combustible liquid transported in a non-bulk packaging is not subject to the HMR unless it is a hazardous substance, a hazardous waste, or a marine pollutant (§ 173.150 (f) (2)) • I hope this satisfies your request. Sincerely, Office of Hazardous Materials 000196 173.150(f)#
Page 2FROM : TANDEM TECHNOLOGIES INTL FAX NO. : 770 830 1503 Jul. 10 2000 11:32AM P1 Fandem Lechnologies 150 international 8173. 00-0196 ATTN; JEFF FURR DEPT. OF TRANSPORTATION RESEARCH AND SPECIAL PROGRAMS ADMINISTRATION 400 SEVENTH ST. S.W. WASHINGTON, D.C. 20590 JEFF; I AM REQUESTING WRITTEN CONFIRMATION ON THE SUBJECT OF COMBUSTIBLE LIQUIDS. WE ARE FORMULATING A PRODUCT THAT MEETS THE DEFINITION OF A COMBUSTIBLE • LIQUID UNDER 173.120 (B). THIS PRODUCT HAS A FLASH POINT OF 142 -144 DEGREES. WHEN SHIPPED IN NON-BULK PACKAGINGS I.E., 5 GAL PAILS AND 55 GAL. DRUMS, DOES THE PRODUCT GET REMOVED FROM THE HMR ALTOGETHER. IT IS OUR UNDERSTANDIN THAT IT DOES GET REMOVED FROM THE HMR, AND WE COULD THEN SHIP THE PRODUCT AS A "CLEANING COMPOUND- NON-HAZARDOUS." THE COMPOSITION OF THIS PRODUCT IS A MIXTURE OF PETROLEUM DISTILLATES AND COSOLVENTS THAT ARE NOT HAZARDOUS WASTES. WE FEEL THAT OUR PRODUCT IS EXEMPT FROM THE HMR UNDER 173.150: PLEASE TELL US IF WE ARE CORRECT. YOU CAN SEND YOUR RESPONSE LETTER TO: TANDEM TECHNOLOGIES INT'L, 108 COLUMBIA WAY, CARROLLTON, GA. 30117 OR TO TTI. P.O. BOX 1125 CARROLLTON, GEORGIA, 30117. • THANK YOU, R. JETT• RICH PRESIDENT. Envirormextal Аншегь Through Chemistry P.O. Box 1125 • Carrollton, Georgia 30117 » (404) 830-1958 100% Recycled#
This material provides agency context. It does not replace binding regulatory text, and its legal effect depends on the underlying authority and facts.