Meals Ready-to-Eat (MRE) Heater

This responds to your letter requesting clarification of the requirements for shipping your product, a new individual food heater inside of a meals, ready-to-eat (MRE) ration package. Specifically, you asked whether the individual food heater, containing a Division 5.1 (oxidizer), in Packing Group II, and glycerin-water solution, would be excepted from the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). A facsimile of several photographs of the individual food heater, MRE ration package, and accompanying test report were enclosed. You provided information, as follows:

The individual food heater consists of two pouches with a total of 29.9 grams of potassium permanganate. Each of the hermetically sealed, vacuum packed pouches contains approximately 15 grams of potassium permanganate. The potassium permanganate is covered with an inert coating and meets the definition of Division 5.1 (Oxidizer) in Packing Group II, tested in accordance with the UN Manual of Tests and Criteria, 34.1, Test 0.1, as specified in § 173.127(a)(1). The amount of oxidizer in the combined two-pouch heater is less than the reportable quantity (RQ) of potassium permanganate (RQ, 100 lbs.) per package, and each pouch weighs 22.6 grams. The fuel is a glycerin-water solution. When the fuel pouch is ruptured, the fuel spreads throughout the oxidizer; the water slowly dissolves the coating of the permanganate crystals, which then react with the glycerin.

Based on the information you provided, it is our determination that the individual food heater described above when shipped as components of a MRE ration package is subject to the requirements of the HMR. This determination also applies to the individual food heater devices when shipped separately from MREs. The MRE ration package, containing an individual food heater, may qualify for the limited quantity or consumer commodity packaging exceptions specified in § 173.152(b) and (c), respectively, for Division 5.1 (oxidizers), or the small quantity packaging exceptions in § 173.4.

I hope this satisfies your inquiry. If we can be of further assistance, please contact us.