{"operation":"document","citation":"05-0304","title":"Photographic Solutions, Inc. — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2006-01-17","effective_on":null,"summary":"05-0304 response to Photographic Solutions, Inc. concerning 175.10.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-05-0304.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-05-0304.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-05-0304","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2005/050304.pdf","body":"<<<PAGE 1>>>\n\nJAN 17 2006\nMr. David Stone\nRef. No. 05-0304\nPhotographic Solutions, Inc.\n7 Granston Way\nBuzzards Bay, MA 02532\nDear Mr. Stone:\nThis is in response to your November 28, 2005 letter requesting clarification of the\nHazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Your company\nproduces a liquid cleaning solution used by photographers. The cleaning solution\nconsists of 100% purified methanol, and is packaged in 2 oz. (59 mL) plastic receptacles.\nSpecifically, you ask if passengers may transport your company's product in checked or\ncarry-on baggage aboard aircraft.\nA passenger may not transport a hazardous material in checked or carry-on baggage\nunless the material meets one of the exceptions in § 175.10. Methanol is listed in the\nHazardous Materials Table (HMT; § 172.:01) as a Class 3 (Flammable liquid) material,\nand does not meet any of the exceptions specified in § 175.10. Therefore, your product is\nnot permitted to be carried aboard an aircraft in a passenger's checked or carry-on\nbaggage under the HMR.\nSincerely,\nChief, Standards Development\nOffice of Hazardous Materials Standards\n175.10\n050304\n\n<<<PAGE 2>>>\n\n25-0304\nDear USDOT,\nMy company sells a liquid cleaner (called Eclipse) consisting of 100% purified methanol\nsold in 2 oz (59mL) plastic dropper bottle containers. It is used by professional and amatuer\nphotographers in conjunction with our Sensor Swab Digital Imaging Chip Cleaner (a fancy\nQ-tip with no chemicals). A new, unopened bottle has a foil seal across the neck designed\nto be leak proof and a plastic screw cap to protect the seal. The cap must be turned\napproximately 2 full rotations to be removed. The bottle is a white HDPE plastic which is\nimpervious to the chemical.\nAs many of these photographers need to travel, and need to carry a cleaning kit with them to\nuse while shooting, the question has come up as to whether or not such a container would\nbe permissible to bring in carry-on or in checked luggage. It appears that some TSA\ncheckpoints do not allow it and others look at the container and have no issue with it.\nI am hoping that DOT can clarify in writing its position so I can advise my customers\naccordingly.\nAn MSDS and other product information can be found on our company web site at :\nhttp://www.photosol.com\nor please feel free to contact me at (508) 759 2322.\nThank-you.\nDavid M. Stone, PHOTOGRAPHIC SOLUTIONS, INC.\nhttp://www.phetosol.com\n7 Granston Way Buzzards Bay, MA 02532\n(508) 759-2322 phone; E.S.T or E. D. T.\nuse this i-name to contact me personally. It is spam proof!!!\nhttp://public.xdi.org/=David.Stone\n11/28/2005","truncated":false,"body_characters":2611}