{"operation":"document","citation":"98-0545","title":"Mr. Robert C. Franz — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1998-01-06","effective_on":null,"summary":"98-0545 concerning 173.186.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-98-0545.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-98-0545.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-98-0545","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/1998/980545.pdf","body":"<<<PAGE 1>>>\n\nof Transportation\nU.S.Department\nJAN\n6 1998\n0 Seventh Street, S.\nResearch and\nashington, D.C. 205!\nSpecial Programs\nAdministration\nMr. Robert C. Franz\n61 Roosevelt Boulevard\nFlorham Park, NJ 07932\nDear Mr. Franz:\nThis is in response to your letter dated September 27, 1997, regarding the transportation of\nsafety matches under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).\nSpecifically, you ask why safety matches are regulated under the HMR.\nSafety matches are regulated as a Division 4.1 (flammable solid) material. Section 173.124\n(a)(3)(i) defines one category of readily combustible solids as materials that are solids which\nmay cause a fire through friction, such as matches. Safety matches meet this definition and\nare regulated under the HMR. The Hazardous Materials Table (HMT) in § 172.101 lists\n\"Matches, safety (book, card or strike on box)\" as a proper shipping name.\nColumn (8A) of the HMT lists an exception for safety matches under § 173.186. Section\n173.186 (c) states that safety matches must be tightly packed in securely closed inner\npackagings to prevent accidental ignition under conditions normally incident to\ntransportation, and further packed in outer fiberboard, wooden, or other equivalent-type\npackagings. These matches in outer packagings not exceeding 23 kg (50 Ibs.) gross weight\nare not subject to any other requirement (except marking) of the HMR. These packagings\nmay be packed in the same outer packaging with materials not subject to the HMR. Those\nwho offer for transportation packages of safety matches which exceed 23 kg must adhere to\nall the requirements of the HMR including shipping papers, marking, labeling, placarding,\nand training. Section 171.11 authorizes the use of the International Civil Aviation\nOrganization's (ICAO) Technical Instructions as an alternative to 49 CFR for air shipments.\ni\nHowever, ICAO does not provide the 23 kg exception for safety matches.\nPlease note that the United States Post Office has its own set of hazardous materials\n:\ntransportation guidelines. Shipments of hazardous materials made via the United States\nPostal Office are not subject to the HMR.\nI hope this information is helpful. If you need further assistance, please do not hesitate to\ncontact us.\nOn Hillip,\n:\nDelmer F. Billings\nChief, Regulations Development\nOffice of Hazardous Materials Standards\n\n<<<PAGE 2>>>\n\nROBERT C. FRANZ\n61 ROOSEVELT BOULEVARD\nFLORHAM PARK, NEW JERSEY 07932 File 113,186\n(201) 377-8275\n50: 518\nMr. Edward Muzzullo\nHazardous Materials Safety\nResearch and Special Program Administration\n400 7th Street S.W.\nWashington, DC 20590\nSeptember 27,1997\nDear Mr. Mazzullo:\nDuring my travels over the past\nup matchbooks from hotels, restaurants, bars, etc., as most\n30 years I generally picked\ntravelers do. On an overseas trip I sometimes\n20 or 30 books or boxes from different countries. These of\nwould collect\ncourse are all safety matches. Strike anywhere matches I\nbriefcase and sometimes in my checked luggage.\ndon't think exist anymore. Sometimes I would carry them in my\nby the FAA as a \"dangerous material\". From what they sent me\nmatchbooks are lumped in with all sorts of things that can\nexplode. I'm sure you are aware that it is impossible for\nsafety match to ignite by itself or rubbing it on any surface\nother than the strike surface to obtain the other chemical.\nTherefore I am at a loss to understand why there is such an\nantiquated regulation still on the books, that was probably\nwritten for the strike anywhere matches.\nPerhaps you are aware that the post office in their\n\"Hazardous Matter\" regulation (C023.3.5) permits mailing up\nto 50 pounds of matchbooks. NOw of\ngoes by air, which is a bit confusing. I belong to three\ncourse most of the mail\ntime, and these packages undoubtedly were transported by air.\nmatchbook clubs and we trade back and forth by mail all the\nHas any thought been given to bringing the FAA regulation up\nto date? Would appreciate hearing from\n• you.\nSincerely,\nPale a Frang","truncated":false,"body_characters":4010}