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Interpretation Response #00-0096 ([Huntsman Corporation] [Mr. Philip Abraham])

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

Interpretation Response Details

Response Publish Date:

Company Name: Huntsman Corporation

Individual Name: Mr. Philip Abraham

Location State: TX Country: US

View the Interpretation Document

Response text:

June 14, 2000

Mr. Philip Abraham                Ref. No. 00-0096
Huntsman Corporation
Room 501
3040 Post Oak Blvd.
Houston, TX 77056

Dear Mr. Abraham:

This is in response to your letter dated March 30, 2000, regarding determination of a proper shipping name under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Specifically, you ask whether "mines, liquid corrosive, flammable, nos (Technical name), 8, UN 2734, APG II" is the most appropriate shipping description for an amine that meets the HMR criteria for Class 8 Packing Group II, Class 3 Packing Group III, and Division 6.1 Packing Group III?

The answer is yes.  Section 172.101(c)(12)(iii)-states that if the material meets, the definition of more than one hazard class and is not identified specifically by name in the Hazardous Materials Table, then the hazard class of the. material shall be determined by using the precedence specified in §173.2a. In your scenario, Class 8 Packing Group II takes precedence followed by Class 3 Packing Group III, then­ Division 6.1 Packing Group III.  Therefore, the proper shipping description for the hazardous material is "mines, liquid, corrosive, flammable, nos (Technical name)  8, UN 2734, PG II." In addition, subsidiary hazard class or division numbers may be entered following the numerical hazard class, or following the basic description (§172.202(a)(2)).

Section 172.203(m) states that if a material meets the definition of Division 6.1, Packing Group I or II, and the fact that it is toxic is not disclosed in the shipping name or class entry, then the word  "Poison" or "Toxic"  shall be entered on the shipping paper in association with the shipping description.  Therefore, the term "Poison" or  "Toxic" does not have to be included in the proper shipping description for a material that meets the definition for Division 6.1 Packing Group III.  However, §172.402(a)(2) states that for a material meeting Division 6.1 (regardless of the packing group), a POISON hazard label is required in addition to any other required labels.

I hope this satisfies your request.
Sincerely,

John A. Gale
Transportation Regulations Specialist
Office of Hazardous Mater

172.203

Regulation Sections