Interpretation Response #05-0282 ([Akzo Nobel Chemicals Inc] [Mr. Mark A. Connolly])

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

Interpretation Response Details

Response Publish Date: 11/22/2005

Company Name: Akzo Nobel Chemicals Inc

Individual Name: Mr. Mark A. Connolly

Location State: IL Country: US

View the Interpretation Document

Response text:

Nov 22, 2005

Mr. Mark A. Connolly                              Reference No. 05-0282
Manager Transportation Regulations and Security
Akzo Nobel Chemicals Inc
300 South Riverside Plaza
Chicago, IL 60606-6697

Dear Mr. Connolly:

This is in response to your October 19, 2005 letter regarding entry of the subsidiary hazard class or division on shipping papers under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Your questions are paraphrased and answered as follows:

Q1.      Under § 172.202(a), the subsidiary hazard class or division must be entered in parentheses immediately following the primary hazard class on shipping papers. Does this requirement only apply to subsidiary hazard classes when specifically noted in Column 6 of the § 172.101 Table?

Al.      No. If it is specifically determined that a material meets the defining criteria for a subsidiary hazard that is not shown in Column 6 of the § 172.101 Table for that material, the material must be identified on the shipping paper as having that subsidiary hazard class in accordance with § 172.202(a).

Q2.      Is the notation “(1)” as the subsidiary hazard entry on a shipping paper acceptable for a material identified in Column 6 of the § 172.101 Table as having an explosive subsidiary hazard?

A2.      Yes. A material identified in Column 6 of the § 172.101 Table as having an explosive subsidiary hazard is not assigned to a specific division or compatibility group. Therefore, the number “1” placed in parentheses is the appropriate subsidiary hazard class entry on the shipping paper.

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

Sincerely,

Hattie L. Mitchell
Chief, Regulatory Review and Reinvention
Office of Hazardous Materials Standards

172.202(a)(2)

Regulation Sections