Interpretation Response #03-0201 ([Gulf Trading (Alabama), Inc.] [Mr. Mark Walker])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Gulf Trading (Alabama), Inc.
Individual Name: Mr. Mark Walker
Location State: PA Country: US
View the Interpretation Document
Response text:
Nov 21, 2003
Mr. Mark Walker               Reference No.: 03-0201
  Sr. Vice President 
  Gulf Trading (Alabama), Inc. 
  1100 Washington Ave., Suite 312 
  Carnegie, PA 15106-3617 
Dear Mr. Walker:
This is in response to your letter concerning the classification of Calcium Silicide under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You submitted test data based on the classification criteria in the UN Manual of Tests and Criteria which indicates your material contains 27.07% Calcium and 55.75% Silicon. It is your opinion that the material does not meet the definition of a Division 4.3 Dangerous when wet material.
Under § 173.22, it is the shipper's responsibility to classify a hazardous material. This office does not normally perform this function. However, based on the test data you submitted, it is the opinion of this office that your material does not meet the definition of a Division 4.3 material and provided it does not meet any other hazard class, it is not subject to the HMR.
I hope this satisfies your inquiry.
Sincerely,
Hattie L. Mitchell 
  Chief, Regulatory Review and Reinvention 
Office of Hazardous Materials Standards 
Regulation Sections
| Section | Subject | 
|---|---|
| 173.22 | Shipper's responsibility |