Interpretation Response #15-0209 ([Renessenz LLC.] [Mr. John Hinson])

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date: 02/23/2016

Company Name: Renessenz LLC.

Individual Name: Mr. John Hinson

Location State: FL Country: US

View the Interpretation Document

Response text:

February 23, 2016

Mr. John M. Hinson
Manager, Strategic Raw Materials
Renessenz LLC.
601 Crestwood St.
Jacksonville, FL 32208

Reference No. 15-0209

Dear Mr. Hinson:

This is in response to your October 14, 2015 email, requesting clarification on the correct basic description for crude sulfate turpentine solution (CST). Specifically, you ask whether the most appropriate proper shipping name for this commodity is "UN1993, Flammable liquids, n.o.s., Class 3" or "UN1299, Turpentine, Class 3." You note that depending on the amount of sulfur compounds present in the solution, the flash point may result in either a packing group II or III assignment. For UN1299, the § 172.101 Hazardous Materials Table (HMT) only contains a packing group III entry.

Section 172.101(c)(10) sets forth the criteria for selecting a proper shipping name of a mixture or solution not identified specifically by name in the HMT. Section 172.101(c)(10)(i) requires that a mixture or solution comprised of a single predominant hazardous material identified by technical name in the HMT and one or more hazardous and/or non-hazardous material must be described with the proper shipping name of the predominant hazardous material and the qualifying word "mixture" or "solution," unless the mixture or solution meets one or more of the conditions in subparagraphs (i)(A) through (F).

The CST you describe is in solution that is not identified by name in the HMT, but is comprised of a single predominant hazardous material (Turpentine) identified in the HMT by technical name and one or more hazardous and/or non-hazardous materials. As such, the most appropriate basic description for the CST assigned to PG III is "UN1299, Turpentine solution, Class 3, PG III." However, in accordance with § 172.101(c)(10)(i)(C), CST meeting the criteria for PG II may not be described as "UN1299" because the packing group of the solution is different from that specified in the entry. A solution of turpentine meeting the criteria of a PG II flammable liquid and no other hazard class must be assigned to an appropriate description such as "UN1993, Flammable liquids, n.o.s." The requirements for generic or "n.o.s." proper shipping name selection in § 172.101(c)(10)(iii) are intended for mixtures or solutions not comprised of a single predominant hazardous material identified in the HMT.

I trust this information is helpful. If you have further questions, please do not hesitate to contact this office.

Sincerely,

Duane A. Pfund
International Standards Coordinator
Standards and Rulemaking Division

172.101, 172.101(c)(10), 172.101(c)(10)(i), 172.101(c)(10)(i)(C), 172.101(c)(10)(iii)

Regulation Sections