Interpretation Response #23-0017

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

Interpretation Response Details

Response Publish Date: 07/12/2023

Company Name: Vantage Specialties, Inc.

Individual Name: Mr. Donovan Robin

Location State: IL Country: US

View the Interpretation Document

Response text:

July 12, 2023

Mr. Donovan Robin
Regulatory Affairs Manager
Vantage Specialties, Inc.
3938 Porett Drive
Gurnee, IL  60031

Reference No. 23-0017

Dear Mr. Robin:

This letter is in response to your February 27, 2023, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the transportation of an environmentally hazardous substance. Specifically, you ask how a mixture containing "1-Bromopropane" should be treated under the HMR.

Appendix A to § 172.101 of the HMR—List of Hazardous Substances and Reportable Quantities—provides the materials and their corresponding reportable quantities (RQs) that are listed or designated as "hazardous substances" under section 101(14) of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA; 42 U.S.C. 9601 et seq). As of today, the Environmental Protection Agency has included "1-Bromopropane" on its list of hazardous substances, but the Pipeline and Hazardous Materials Safety Administration (PHMSA) has not yet added this material to Appendix A to § 172.101.

While PHMSA conducts its rulemaking process to potentially add "1-Bromopropane" to the list of hazardous substances in Appendix A to § 172.101, it is the opinion of this Office that "1-Bromopropane" may be shipped as "RQ, NA3082, Other regulated substances, liquid, n.o.s., (1-Bromopropane mixture, non-flammable), 9, III."

I hope this information is helpful. Please contact us if we can be of further assistance.

Sincerely,

T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division

172.101

Regulation Sections