Interpretation Response #08-0103 ([Anodamine, Inc.] [Mr. Paul R. Hattingh])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Anodamine, Inc.
Individual Name: Mr. Paul R. Hattingh
Location State: TX Country: US
View the Interpretation Document
Response text:
May 23, 2008
Mr. Paul R. Hattingh
Anodamine, Inc.
2590 Oakmont Drive, Suite 310
Round Rock, TX 78665
Ref. No.: 08-0103
Dear Mr. Hattingh:
This is in response to your April 14, 2008 letter regarding the applicability of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) to cyclohexylamine in concentrations of 13-15 percent.
It is the shipper's responsibility to properly class and describe a hazardous material. This Office does not perform that function. The definitions for flammable liquid and corrosive liquid are found in §§ 173.120 and 173.136 respectively. If you determine that your concentration does not meet either hazard class, and presuming the solution does not meet any other hazard class under the HMR, the material would not be regulated. In response to your second question, if the material meets the definitions of a flammable liquid and a corrosive liquid, and is a packing group II, then the entry "Cyclohexylamine, 8, (3), UN2357, PGII" is an appropriate description.
I hope this information is helpful. If you have further questions, please do not hesitate to contact this office.
Sincerely,
Hattie L. Mitchell
Chief, Regulatory Review and Reinvention
Office of Hazardous Materials Standards
173.120 173.136
Regulation Sections
| Section | Subject |
|---|---|
| 173.120 | Class 3-Definitions |
| 173.137 | Class 8-Assignment of packing group |