{"operation":"document","citation":"99-0134","title":"Sullivan and Guldin — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1999-08-10","effective_on":null,"summary":"99-0134 response to Sullivan and Guldin concerning 173.151.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-99-0134.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-99-0134.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-99-0134","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/1999/990134.pdf","body":"<<<PAGE 1>>>\n\n:\nU.S.Department\nof Transportation\nResearch and\nSpecial Programs\nAdministration\nAUG 1 O 1999\nMr. Dave Guldin\nRef. No.\n99-0134\nSullivan and Guldin\n317 Iroquois Lane\nSeymos, TN\n37865\nDear Mr. Guldin:\nThis is in response to your letter dated May 12, 1999,\nconcerning the requirements for classifying your product under\nthe Hazardous Materials Regulations (HMR; 49 CFR Parts 171-\n180). Specifically, you ask if your product \"Alaskan Fire\nMite\" can be classified as a consumer commodity.\nThe answer to your question is no. Based upon the information\nwe have received, it appears that your product has the\npotential of being a self-ignition source.: If that is\n• the\ncase, your product is forbidden from transportation in\ncommerce based on the requirements of § 173.21.\nTo be of further assistance in classifying your product, we\nneed additional specific information on how the device\nfunctions. This includes specific information and test\nresults on the ignition method and tests required by\nSS 173.124 and 173.186 (a).\nIf you have further questions, please do not hesitate to\ncontact this Office.\nSincerely,\nDelmer F. Billings\nChief, Standards Development\nOffice of Hazardous Materials Standards\n173.151\n990134\n\n<<<PAGE 2>>>\n\n•\nL\n5XG\nNelson\n1022 Dunton St ~ Ketchikan, Alaska 99901\nSullivan and Guidin\n173.15/\n•\nPhone (907) 247-7031 ~ Email guidin@ptialaska.net\n99-0134\nMay 12, 1999\nDepartment of Transportation\n400 7th St SW\nOffice of Hazardous Materials Standards\nWashington, DC 20590\nDear Sir or Madam,\nWe would appreciate some clarification on shipping rules for a new product. We want to ensure that we remain in\ncompliance with all applicable federal laws and have done some research into the matter, but want to make sure that\nwe understand the rules correctly.\ninterpretation is correct.\nFirst, let me describe the product and then explain how we interpret the rules. Please advise us in writing if our\nwoodstoves, and fireplaces. The product is manufactured from the following materials: 100% cotton terry cloth,\nThe product is known as the Alaskar Fire Mite™, a product used for starting barbecue grills, campfires,\n45\" long strip of terry cloth and laying strike anywhere matches every 2.5 inches. Melted paraffin wax is then poured\nsemi-refined paraffin wax, and strike anywhere matches. The manufacturing process involves taking a 3\" wide by\nover the strip and the strip is rolled into a tight cylinder. Each match becomes fully coated in paraffin in this process.\nThe finished product is a 3\" long by 2\" wide cylinder that is very hard, similar to a candie. The matches are\nentirely covered by both wax and the terry cloth. No match touches another, nor does any match touch anything that\nwould allow friction to ignite it. Each match is fully immobilized. Please see attached drawing for reference. We have\ntested this product by placing it in a clothes dryer and tumbling on low heat (app. 105*F) for three hours with no ill\nhazardous concentrations\" as defined under 29 CFR 1910.1200. We also have approached the local fire department\neffects. The paraffin has a melt point of 127*F and a flash point of >350*F and has \"No materials or ingredients in\nto see if they have any concerns with the product and they felt the product was both safe and stable.\n(app. 12 lbs.). Each case will be 200lbs. test cardboard. We intend to ship only by ground.\nEach individual unit is packaged in a poly bag, and we intend to ship in cases of 24 units (app. GIbs.) and 48 units\ngathered together the pertinent CFR regulations. As I understand it,. because the matches are an integral part of the\nIn talking with several people at the DOT, including Michael Stevens, Charles Key, and Linda Cooper, I have\ndo not apply. I believe that the \"Consumer Commodity\" exemption in 49 CFR 173.151 would cover this product.\nproduct, are immobilized, and are safely contained in the product, that the shipping regulations of 49 CFR 173.186\nreclassed as ORM-D material, and would only require labeling as such.\nThe product clearly falls under the definition of Consumer Commodity under 49 CFR 171.8 and would therefore be\nPlease let me know if this interpretation is correct. Fell free to contact me at the above address, phone, or e-mai\nwith any questions you may have. Thanks for your time and attention in this matter.\nSincerely,\nlave Suldi\nEncl: Drawing\nDave Guldin","truncated":false,"body_characters":4366}