"Purging" Zippo lighters
Pipeline and Hazardous Materials Safety Administration · Nov 19, 2007 · Reference No. 07-0191
Interprets: 49 CFR § 172.102
Reggie’s quick take
A company asked whether a purging method for its liquid-fueled, non-pressurized lighters meets the requirements of § 172.102, Special Provision 168 of the hazardous materials rules. The lighters are disassembled and left so the fuel evaporates for at least 24 hours, after which they no longer ignite and only trace amounts of fuel remain. The agency said the test method appears to satisfy Special Provision 168, so lighters purged this way would not be subject to the rules. The agency does not generally endorse one specific purging method.
Written by AI (Claude) on Oct 22, 2026. Robots make mistakes and leave things out, so the letter below is what counts. Not legal advice.
This responds to your letter regarding the applicability of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) to your client, Zippo Manufacturing Company ("Zippo"). Specifically, you ask for confirmation from this office that the "purging" method Zippo is suggesting to its customers for its liquid-fueled, non-pressurized lighters conforms to the requirements in § 172.102, Special Provision 168 of the HMR. You submitted test report results with your request showing that if the lighter is disassembled and the fuel allowed to evaporate for at least 24 hours, the lighter will no longer ignite and only trace (negligible) amounts of fuel remain.
Section 172.102, Special Provision 168, states a lighter that is cleaned and purged of vapors is not subject to the HMR. While this office generally does not endorse a specific method to accomplish this provision, we agree that your suggested test method appears to satisfy this provision. Thus, lighters conforming to this method would not be subject to the HMR.
A letter of interpretation applies the regulations to the facts the requester described. It isn’t a regulation and isn’t legal advice. The agency’s copy.