Interpretation Response #02-0198 ([Applied Biosystems] [David W. Olson])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Applied Biosystems
Individual Name: David W. Olson
Location State: CA Country: US
View the Interpretation Document
Response text:
Aug 28, 2002
Mr. David W. Olson Reference No. 02-0198
Senior Dangerous Goods Specialist
Applied Biosystems
850 Lincoln Centre Drive
Foster City, CA 94404
Dear Mr. Olson:
This responds to your July 26, 2002 letter requesting clarification on the proper shipping name assigned to your material under an approval dated April 5, 2001 for EX-0104016 for "Flammable liquid n.o.s. (1H-tetrazole solution in acetonitrile)." Specifically, you request clarification on why the proper shipping name assigned under the approval was selected instead of the proper shipping name "Acetonitrile solution."
According to your July 26, 2002 letter with enclosures and test data, you conclude that the more appropriate proper shipping name for your product is "Acetonitrile solution". You have concluded that 1H-tetrazole, when added to acetonitrile at a concentration of 3.1 percent, does not contribute to the hazard of your product, therefore, the proper shipping name is "Acetonitrile solution."
Based on the current approval issued on April 5, 2001 and your follow-up letter and data, the explosive properties of 1H-tetrazole solution in acetonitrile presents a hazard in transportation that must be identified for emergency response purposes. Therefore, it remains the opinion of this Office that the most appropriate shipping name for your product is "Flammable liquid, n.o.s. (1H-tetrazole solution in acetonitrile)," not "Acetonitrile solution."
I hope this answers your inquiry.
Sincerely,
Delmer F. Billings
Chief, Standards Development
Office of Hazardous Materials Standards
173.56