Interpretation Response #06-0027
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Jul 6, 2006
Mr. Steve Kranyec
Reference No. 06-0027
2500 W. Main Street G16
League City, TX 77573
Dear Mr. Kranyec:
This responds to your letter regarding the applicability of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171 180) to lighters that no longer contain fuel. Specifically, you ask about requirements applicable to a lighter that has been purged of all fuel and a lighter containing residue amounts of fuel. I apologize for the delay in responding and any inconvenience it may have caused.
It is ultimately the shipper's responsibility to ascertain whether a lighter is or is not subject to the HMR. A lighter that contains no fuel (residual or otherwise) is not subject to the HMR. Most lighter manufacturers provide specific instructions to assist their customers to purge or drain lighters to satisfy the requirements of the HMR. Typically this process may consist of bleeding or purging the fuel reservoir in a gas-fueled lighter until it is empty (e.g., no longer contains liquefied gas or its vapors) or, for a "wick" style liquid-fueled design, removing both the wick and cotton fuel absorbing insert. Generally, if a lighter is purged or drained in accordance with the manufacturer's instructions and the lighter will no longer ignite, it is not subject to the HMR.
There is no certification required by the HMR to show compliance with this requirement.
I trust this satisfies your inquiry. Please contact us if we can be of further assistance.
Hattie L. Mitchell
Chief, Regulatory Review and Reinvention
Office of Hazardous Materials Standards
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