Interpretation Response #98-0413 ([Sierra Chemical, Co.] [Mr. Ron Shan])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Sierra Chemical, Co.
Individual Name: Mr. Ron Shan
Location State: NY Country: US
View the Interpretation Document
Response text:
FEB 12, 1998
Mr. Ron Shan
Sierra Chemical, Co.
P.O. Box 12550
Sparks, NY 89510
Dear Mr. Shan:
This is in response to your letter concerning the use of the proper shipping description "Hypochlorite solutions, 8, UN 1791, PG III" for your product containing 12.5 percent sodium Hypochlorite solution by weight and 87.5 percent of an inert ingredient. You stated that your company was cited by the California Highway Patrol for not including "(sodium Hypochlorite solution)" as a part of the shipping description. You also stated that this material is packaged in containers varying in size from 5 gallons to one cargo tank, and enclosed copies of your shipping paper for our review. I apologize for the delay in responding and any inconvenience this may have caused.
Based on your enclosed shipping papers, when shipped in a cargo tank, the Sodium Hypochlorite meets or exceeds its 100 lb. reportable quantity listed in Appendix A to 49 CFR 172.101, and, therefore, is regulated as a hazardous substance. See § 171.8. Section 172.203(c) provides that, if the proper shipping name does not identify the hazardous substance by name, the name of the hazardous substance must be entered in parentheses in association with the basic description. This section also requires that the letters "RQ" appear either before or after the basic description for a hazardous substance.
Please note that the required shipping description means the basic description required by
§ 172.202 and additional description information required by § 172.203. Section 172.202 prescribes that the basic description consisting of the proper shipping name for the material, as identified in § 172.101 of the Hazardous Material Table, the hazard class, the identification number and the packing group, if any, must be shown in sequence with no additional information interspersed.
Additional information, such as that prescribed by § 172.203, or other additional information concerning a hazardous material must be placed after the basic description on a shipping paper, except that certain notations such as "RQ" may appear before the proper shipping name, and a technical name or chemical group name for a generic description may follow the proper shipping name. Other information allowed to be placed before the basic description is quantity shipped, and the type of packaging and destination marks (see § 172.201 (a)(2)(iii), § 172.201 (a)(4) and § 172.202 ( c)). For example, shipping papers that are designed in columnar form may have the quantity shipped and type of packaging, e.g., "19 drums" entered before the basic description.
Other information such as the item number, quantity ordered, or back order must be entered on the shipping paper after the basic description.
I hope this information is helpful. Please contact us if we can assist you further.
Sincerely,
Hattie L. Mitchell, Chief
Regulatory Review and Reinvention
Office of Hazardous Materials Standards
172.203(k)
Regulation Sections
| Section | Subject |
|---|---|
| 172.203 | Additional description requirements |