Interpretation Response #04-0073 ([MOL America, Inc] [Mr. Fumie Sloan])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: MOL America, Inc
Individual Name: Mr. Fumie Sloan
Location State: CA Country: US
View the Interpretation Document
Response text:
May 18, 2004
Mr. Fumie Sloan Reference No. 04-0073
Supervisor - Hazmat
MOL America, Inc.
One Concord Center
2300 Clayton Road, Suite 1500
Concord, CA 94520
Dear Mr. Sloan:
This responds to your letter concerning the technical name f6r “Self-Reactive Solid, Type D, 4.1, UN 3226, PG II” under the Hazardous Materials Regulations (HMR; 49 CFR parts 171-180). It is your opinion that “modified Azodicarbonamide” as shown on the Dangerous goods declaration is not an acceptable technical name because it is not listed as a technical name in the § 173.224(b) table of the HMR or in the 2.4.2.3.2.3 table of the International Maritime Dangerous Goods (IMDG) Code.
You are correct; “modified Azodicarbonarnide” is not an acceptable technical name under the HMR and the IMDG Code. A self-reactive material that is not identified by technical name in the Self-Reactive Materials Table of § 173.224(b) of the HMR must be approved by the Associate Administrator under the provisions of § 173.124(a) (2) (iii). Similarly, under the IMDG Code, classification of new self-reactive substances or formulations that are not listed in the 2.4.2.3.2.3 table and assignments to a generic entry must be made by the competent authority of the country of origin. Classification procedures, test methods, and criteria relating to self-reactive substances of Division 4.1 are found in the United Nations Transport of Dangerous Goods Manual of Tests and Criteria, Part II.
I trust this satisfies your request.
Sincerely,
Hattie L. Mitchell
Chief, Regulatory Review and Reinvention
Office of Hazardous Materials Standards
172.101, 173.224