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Interpretation Response #99-0039 ([BP Oil Company] [Mr. J. J. Quandt])

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

Interpretation Response Details

Response Publish Date:

Company Name: BP Oil Company

Individual Name: Mr. J. J. Quandt

Location State: OH Country: US

View the Interpretation Document

Response text:

APR 22, 1999

 

Mr. J. J. Quandt                              Ref. No. 99-0039
BP Oil Company
200 Public Square
Cleveland, OH 44114-2375

Dear Mr. Quandt:

This is in response to your letter dated February 1, 1999, regarding requirements to identify marine pollutants on shipping papers under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180,).  Specifically you ask if you may describe leaded gasoline on a shipping paper as "Gasoline (leaded), 3, UNl203, PG II, Marine Pollutant."..,

The answer is yes.  Section 172.203(1)(l)states that if a proper shipping name for a material that is a marine pollutant does not identify the component making it a marine pollutant, the name of that component must appear in parentheses in association with the basic description.  The shipping name "Gasoline" and the description "Marine Pollutant" which appear as part of the shipping description are sufficient to identify the marine pollutant "Gasoline, leaded." It is the opinion of this Office that the description "Gasoline, (leaded), 3, UN1203, PG II, Marine Pollutant" is also an acceptable description for leaded gasoline.

I hope this satisfies your request.

Sincerely,

 

Delmer F. Billings
Chief, Standards Development
Office of Hazardous Materials Standards

172.203

Regulation Sections