Small Quantity Exception
Pipeline and Hazardous Materials Safety Administration · Aug 27, 1996 · Reference No. 96-0107
Interprets: 49 CFR § 173.4
Reggie’s quick take
Someone asked whether 5 ml vials of an ethyl alcohol medicine, shipped as Medicines, n.o.s. (Ethyl alcohol), 3, NA 1993, PG III, can move domestically by motor vehicle, rail, or aircraft under § 173.4. Each outer package holds ten vials, each in its own carton. The agency says yes for domestic shipping, if the inner vials meet § 173.4(a)(2). For air, most carriers accept packages prepared under ICAO Technical Instructions (§ 171.11), which allow the description "Consumer commodity, 9, PG III."
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 inquiry concerning the exceptions for small quantities provisions in 49 CFR 173.4.
You asked if vials containing "Medicines, n.o.s. (Ethyl alcohol), 3, NA 1993, PG III" may be transported domestically by motor vehicle, rail car, and aircraft and internationally by aircraft under § 173.4. You state that each outer package contains ten 5 ml vials. Each vial is packed in an individual carton, and wrapped 5 cartons to a sleeve with cellophane.
For domestic transportation, the answer is yes if the inner vials meet the criteria prescribed in § 173.4(a)(2). Most air carriers accept shipments prepared n accordance with the International Civil Aviation Organization (ICAO) Technical Instructions. See § 171.11. Under the ICAO regulations, the material may be shipped as "Consumer commodity, 9, PG III."
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.