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Interpretation Response #00-0099 ([Oakite Products, Inc.] [Mr. Barry L. Dance])

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

Interpretation Response Details

Response Publish Date:

Company Name: Oakite Products, Inc.

Individual Name: Mr. Barry L. Dance

Location State: MI Country: US

View the Interpretation Document

Response text:

April 21, 2000

Mr. Barry L. Dance                Ref. No. 00-0099
Oakite Products, Inc.
Corporate Transportation Manager
13177 Huron River Drive
Romulus, MI 48174

Dear Mr. Dance:

This is in response to your letter dated March 29, 2000 regarding the definition of a hazardous substance under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).

Under §171.8, a hazardous substance is defined as a material, including its mixtures and solutions, that: (1) is listed in Appendix A to §172.101 of the HMR; (2) is in a quantity, in one package, which equals or exceeds its reportable quantity; and (3) is in a concentration by weight which equals or exceeds the concentration corresponding to the RQ of the material, as shown in the table under §s171.8.

In your letter, you state that your company packages sodium hydroxide (47 percent concentration) in three different packages, one containing 1,410 pounds of sodium hydroxide, and two other packages each containing less than 1,000 pounds of sodium hydroxide.  Sodium hydroxide has an RQ of 1,000 pounds.  To meet the definition of a hazardous substance, the quantity of sodium hydroxide in each package must equal or exceed 1,000 pounds and 2 percent concentration by weight.  You are correct in your understanding that only the package containing 1,410 pounds of sodium hydroxide meets the definition of a hazardous substance.

I hope this satisfies your request.

Sincerely,

John A. Gale
Transportation Regulations Specialists
Office of Hazardous Materials Standards

 

171.8

Regulation Sections

Section Subject
171.8 Definitions and abbreviations