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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #00-0067 ([Air Freight Center, Inc.] [Mr. William Warder])

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

Interpretation Response Details

Response Publish Date:

Company Name: Air Freight Center, Inc.

Individual Name: Mr. William Warder

Location State: MO Country: US

View the Interpretation Document

Response text:

April 4, 2000

Mr. William Warder                Ref. No. 00-0067
Air Freight Center, Inc.
Kansas City International Airport
P.O. Box 20104
Kansas City, MO 64195-0104

Dear Mr. Warder:

This is in response to your letter dated February 29, 2000, and subsequent telephone conversation with a member of my staff regarding the applicability of a vinegar solution (acetic acid) to the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Your questions are paraphrased and answered as follows:

Ql.          Does the U.S. Department of Transportation and the Food and Drug Administration have a memorandum of understanding on how to properly class vinegar/acetic acid?

Al.          The answer is no.

Q2.         Does the HMR regulate an acetic acid solution that contains vinegar at a concentration greater than 11 percent?

A2.         Any material, regardless of its intended purpose, that meets the definition of a hazardous  material in §171.8 is subject to the HMR.  Under §173.22 of the HMR, it is the shipper's  responsibility to properly class a material.  This office does not perform that function.

Q3.        Can corrosivity test results for a food grade acetic acid solution (e.g., 10 percent vinegar and 90 percent water) be applied to a non-food grade acetic acid solution with the identical concentrations?

A3.         The answer is yes.  DOT does not make a distinction between a food grade and non-food grade acetic acid solution.

We hope this satisfies your request.


John A. Gale

Transportation Regulations Specialist

Office of Hazardous Materials Standards


Regulation Sections

Section Subject
173.22 Shipper's responsibility