Weiman Products, LLC — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Avenue, SE Washington, D.C. 20590 AUG 0 7 ;013 Mr. Matt Malec Process Engineer Weiman Products, LLC 755 Tri-State Parkway Gurnee, IL 60031 Reference No. 13-0130 Dear Mr. Malec: This is in response to your June 12, 2013 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the exception for aqueous solutions of alcohols prescribed in § 173.150( e )(2). Specifically, you ask if this exception permits flammable liquids that are not alcohols to either qualify for this exception or be combined with an alcohol and qualify for this exception. To qualify for the exception prescribed in § 173 .150( e )(2), an aqueous solution of alcohol must contain only alcohol and no other hazardous material, regardless of hazard class. The HMR excepts from regulation an aqueous solution that contain up to 24 percent alcohol by volume, 50 percent or more water, and no other hazardous material other than an alcohol under § 173 .150( e )(2). Although the HMR does not specifically define the term alcohol, it is the understanding of this Office that this term is generally defined in chemical dictionaries and texts to mean any organic compound that has a hydroxyl group (-OH) bound to a carbon atom, which in tum is bound to other hydrogen and/or carbon atoms. I hope this satisfies your request. s[2 - 1 () T. Glenn Fo&~- l) Chief, Regulatory Review and Reinvention Branch Standards and Rulemaking Division#

Page 26.12.2013 U.S. DOT PHMSA Office of Hazardous Materials Standards Attn: PHH-10 East Building 1200 New Jersey Ave, SE. Washington, D.C. 20590 RE: Aqueous Solutions of Alcohol Exception (49 CFR § 173.150(e)) Questions Dear Sir or Madam: We have recently had internal questions regarding the Aqueous Solutions of Alcohol Exception (49 CFR § 173.150(e)). Specifically, as it is stated in 49 CFR § 173.150(e)(2), "An aqueous solution containing 24 percent or less alcohol by volume and no other hazardous material -Is not subject to the requirements of this subchapter if it contains no less than 50 percent water." Where it states "no other hazardous material," does that specifically pertain to other flammable materials since it is referenced in the Exceptions for Class 3 (i.e., flammable) Materials section(§ 173.150)? Thank you for your time. Please contact me using my information below. Sincerely, Weiman Products, LLC -1~~,_ __,-/k . ~- / ,r·· ' ~- / i ./ / Matt Malec Process Engineer Weiman Products, LLC 755 Tri-State Pkwy Gurnee, IL 60031 Phone: 847-856-7290 Fax: 847-856-7390 wvvw. \Veirnan.com Mivialec @weiman.com#