Interpretation Response #11-0021 ([Kajuligan Corporation] [Mr. Clifford Croft])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Kajuligan Corporation
Individual Name: Mr. Clifford Croft
Location State: IL Country: US
View the Interpretation Document
Response text:
April 21, 20111
Mr. Clifford Croft
Director of Regulatory Compliance
Kajuligan Corporation
1533 Kirkwood Drive
Geneva, IL 60134
Ref. No. 11-0021
Dear Mr. Croft:
This responds to your January 18, 2011 request for clarification on the hazard class and proper shipping name for 46% Hydrogen Peroxide in a 3 ml syringe under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You state that the manufacturer is listing the classification as "UN 3139, Oxidizing liquid, n.o.s. (Hydrogen peroxide), 5.1, PG II" on the Material Safety Data Sheet (MSDS). You disagree with the manufacturer"s classification of this material. Specifically, you ask for the proper hazard class and proper shipping name for this product.
As provided in § 173.22, it is the shipper"s responsibility to properly classify a hazardous material. Such determinations are not required to be verified by this office. Additionally, you provided no test data or an MSDS to substantiate your disagreement with the manufacturer"s classification of this material. However, the Hazardous Materials Table (HMT) specifically lists "Hydrogen peroxide, aqueous solution, with more than 40% but less than 60% hydrogen peroxide" as a Division 5.1, and requiring both an OXIDIZER and CORROSIVE label. If the hazard class of the material you describe is questionable, the material should be tested for final hazard class determination.
I hope this answers your inquiry. If you need additional assistance, please contact this office at
202-366-8553.
Sincerely,
Ben Supko
Acting Chief, Standards Development Branch
Standards and Rulemaking Division
173.22
Regulation Sections
| Section | Subject |
|---|---|
| 173.22 | Shipper's responsibility |