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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.

Sincerely,

John A. Gale

Transportation Regulations Specialist

Office of Hazardous Materials Standards

173.22

Regulation Sections

Section Subject
173.22 Shipper's responsibility