Interpretation Response #03-0002 ([Sunoco, Inc.] [Mr. Michael Alston])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Sunoco, Inc.
Individual Name: Mr. Michael Alston
Location State: PA Country: US
View the Interpretation Document
Response text:
Jul 1, 2003
Mr. Michael Alston Reference No. 03-0002
Manager-Regulatory Compliance
Sunoco, Inc.
200 Neville Road
Pittsburgh, PA 15225
Dear Mr. Alston:
This is in response to your letter regarding the description of “waste organic peroxide, Type F, (cumene hydroperoxide) 5.2, UN3109, PG II” under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).
Your letter states that the cumene hydroperoxide has a concentrated mass of £ 90 % and a diluent mass of ³
10 % and the cumene hydroperoxide liquid is totally absorbed in a filter substance that is compatible with the product. You ask whether this material should be described on the shipping paper as a “liquid” or a “solid”. In your opinion, “liquid” better describes the material even though the liquid is totally absorbed in the filter substance.
Based on the information contained in your letter, it is our opinion that the material should be described as a “solid” if no free flowing liquid is Visible surrounding the filter substance. Therefore, for a waste material, a shipping name that appropriately describes the material is “Waste organic peroxide, solid, type F, (filter cartridges containing absorbed cumene hydroperoxide), 5.2, UN3110, PG II.”
I hope this satisfies your request.
Sincerely,
Hattie L. Mitchell
Chief, Regulatory Review and Reinvention
Office of Hazardous Material Standards
172.101
Regulation Sections
| Section | Subject |
|---|---|
| 172.101 | Purpose and use of hazardous materials table |