On February 10, 2021, the Pipeline and Hazardous Materials Safety Administration (PHMSA) issued updated interpretation 20-0082 in response to my request to provide new clarity on how the 24% alcohol exception should be applied. That exception, found in 49 CFR 150(e), has been in the regulations for decades with occasional re-phrasing and editorial changes. The interpretation confirms that aqueous solutions of alcohol and other materials, including listed hazardous materials, if in the concentration as shipped those listed materials do not meet the definition of any hazardous class. An example may be clearer. If a solution of less than 24% alcohol includes ingredients such as an ammonia solution, the 24% exception is available if the ammonia solution, in the concentration present in the product, does not meet the definition of a "hazardous material" in 49 CFR 171.8. In this example, the product contains 1.2% ammonia solution, that is 1.2% by volume in the total solution. Water is the predominant ingredient at 64%, with 20% alcohol. The solution without the alcohol does not meet any hazard class definition. Ammonia solution is shown in the hazardous materials table as Class 8, but it is not corrosive in such a minor percentage.
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