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Interpretation Response #00-0022 ([SC Johnson Wax Professional] [Ms. Laura Bridges])

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

Interpretation Response Details

Response Publish Date:

Company Name: SC Johnson Wax Professional

Individual Name: Ms. Laura Bridges

Location State: WI Country: US

View the Interpretation Document

Response text:

March 17, 2000

Ms. Laura Bridges                Ref.  No. 00-0022
Sr. Packaging Engineer
SC Johnson Wax Professional
8 3 10 1 6th Street
Sturtevant, WI 53177-0902

Dear Ms. Bridges:

This is in response to your letter dated January 8, 2000, requesting clarification on the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180.  Specifically, you ask that when determining whether a Class 8 (corrosive) liquid is organic or inorganic, is it appropriate to consider only those components that cause the material to be corrosive, or to base the determination on the whole mixture (i.e., a corrosive liquid and the remainder being water).

When determining whether a mixture is organic or inorganic, a shipper must make that determination based on the hazardous components in the mixture.  Therefore in your situation, the shipping description should reflect the corrosive constituent in the mixture or solution.

I hope this information is helpful.  If we can be of further assistance, please contact us.

Sincerely,

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

173.22

Regulation Sections

Section Subject
173.22 Shipper's responsibility