Applicability of HMR to "Insitutube"
Pipeline and Hazardous Materials Safety Administration · Dec 11, 1987 · Reference No. 87-0004
Interprets: 49 CFR § 173.115
Reggie’s quick take
A company's lawyer asked whether its product, the "Insitutube," falls under the Hazardous Materials Regulations. The agency reviewed a sample and product information and decided it does not pose a significant hazard in transport, so the regulations do not apply. The decision rests on the quantity and form of the resin solution inside the tube. The letter does not say the answer holds for other quantities or forms, and it does not say anything about other products.
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 is in response to your letter dated October 23, 1987, on behalf of your client, Insituform of North America, Inc., concerning whether your client's product, trade name "Insitutube," is subject to the Hazardous Materials Regulations (49 CFR Part 171-179).
We have reviewed the sample of your client's product and the product information which you submitted to us. Based on the quantity and form of resin solution contained in the "Insitutube", it is our determination, under the provisions of 49 CFR 173.115(g), that the product does not pose a significant hazard during transportation and, therefore, is not subject to requirements of the Hazardous Materials Regulations.
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.