Interpretation Response #00-0067 ([Air Freight Center, Inc.] [Mr. William Warder])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Air Freight Center, Inc.
Individual Name: Mr. William Warder
Location State: MO Country: US
View the Interpretation Document
Response text:
April 4, 2000
Mr. William Warder Ref. No. 00-0067
Air Freight Center, Inc.
Kansas City International Airport
P.O. Box 20104
Kansas City, MO 64195-0104
Dear Mr. Warder:
This is in response to your letter dated February 29, 2000, and subsequent telephone conversation with a member of my staff regarding the applicability of a vinegar solution (acetic acid) to the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Your questions are paraphrased and answered as follows:
Ql. Does the U.S. Department of Transportation and the Food and Drug Administration have a memorandum of understanding on how to properly class vinegar/acetic acid?
Al. The answer is no.
Q2. Does the HMR regulate an acetic acid solution that contains vinegar at a concentration greater than 11 percent?
A2. Any material, regardless of its intended purpose, that meets the definition of a hazardous material in §171.8 is subject to the HMR. Under §173.22 of the HMR, it is the shipper's responsibility to properly class a material. This office does not perform that function.
Q3. Can corrosivity test results for a food grade acetic acid solution (e.g., 10 percent vinegar and 90 percent water) be applied to a non-food grade acetic acid solution with the identical concentrations?
A3. The answer is yes. DOT does not make a distinction between a food grade and non-food grade acetic acid solution.
We hope this satisfies your request.
Sincerely,
John A. Gale
Transportation Regulations Specialist
Office of Hazardous Materials Standards
173.22
Regulation Sections
| Section | Subject |
|---|---|
| 173.22 | Shipper's responsibility |