Interpretation Response #05-0142 ([The AN Group] [Mr. Robert J. Fersterheim])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: The AN Group
Individual Name: Mr. Robert J. Fersterheim
Location State: DC Country: US
View the Interpretation Document
Response text:
Dec 7,2005
Mr. Robert J. Fersterheim Reference No. 05-0142
Executive Director
The AN Group
1250 Connecticut Avenue, N.W
Suite 700
Washington, DC 20036
Dear Mr. Fersterheim:
This responds to your June 1, 2005 letter and subsequent conversations with Ben Supko of my staff requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you request that Acrylonitrile, stabilized, UN1093, PG I be reclassified as a PG II material because it has a flashpoint of approximately 1° C and a boiling point of approximately 77° C, which is consistent with that of a PG II flammable liquid.
A material with a flashpoint of approximately 1° C and a boiling point of approximately 77° C, that meets no other hazard, is best classified as a flammable liquid in Packing Group II However, acrylonitrile also exhibits the subsidiary hazard of Packing Group I poison. In accordance with the precedence of hazard table in § 173.2a(b), a material that meets Class 3, PG II and Division 6.1, PG I is assigned to Class 3. Note 1 following the precedence of hazard table states that the most stringent packing group assigned to a hazard of the material takes precedence over other packing groups. Therefore, a material meeting Class 3 PG II and Division 6.1 PG I is classified as Class 3 PG I.
I hope this information is helpful. Please contact us if you require additional assistance.
Sincerely,
John A. Gale
Chief, Regulations Development
Office of Hazardous Materials Standards
172.101, 173.121