Interpretation Response #01-0061 ([Glencore] [Mr. Michael O'Connell])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Glencore
Individual Name: Mr. Michael O'Connell
Location State: CT Country: US
View the Interpretation Document
Response text:
MAR 7, 2001
Mr. Michael O'Connell                      Ref. No. 01-0061
 Glencore 
  Three Stamford Plaza 
  301 Tresser Boulevard
  Stamford, CT 06901-3244 
Dear Mr. O'Connell:
This is in response your February 27, 2001 letter, regarding the applicability of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) to ferrosilicon, with 65 to 75 percent silicon.
Under § 173.22, it is the shipper's responsibility to properly classify a hazardous material. Such determinations are not required to be verified by this office. However, based on the test results you provided, it is our opinion that the ferrosilicon described in your letter does not meet the criteria of a Division 4.3 and provided it does not meet any other hazard class, is not subject to the HMR.
I hope this satisfies your request.
Sincerely,
John  A. Gale 
   Transportation Regulations Specialists
   Office of Hazardous Materials  Standards 
173.22
Regulation Sections
| Section | Subject | 
|---|---|
| 173.22 | Shipper's responsibility |