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Interpretation Response #00-0193 ([Hazardous Materials Advisory Council] [Mr. Vaughn Arthur])

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

Interpretation Response Details

Response Publish Date:

Company Name: Hazardous Materials Advisory Council

Individual Name: Mr. Vaughn Arthur

Location State: DC Country: US

View the Interpretation Document

Response text:

August 18, 2000


Mr. Vaughn Arthur                                Ref. No. 00-0193
Hazardous Materials Advisory Council
1101 Vermont Avenue, NW, Suite 301
Washington, DC 20005-3521

Dear Mr. Arthur:

This is in response to your letter dated July 10, 2000, regarding a letter of clarification issued by this Office on September 8, 1999,  Reference Number 99-0219.  It is your belief that our response is in error.

In our letter dated September 8, 1999, we stated that an acetic acid solution that is used as a dye, may be described under the shipping name “Acetic acid solution”  or  “Dyes, liquid, corrosive, n.o.s”  It is your opinion that the answer is contrary to the mixtures and solutions proper shipping name selection criteria specified in § 172. 1 01 (c)(I 0) which leads a shipper to “only one final proper shipping name choice.”  Therefore, you conclude, the acetic acid solution should be described under the shipping name “Dyes, liquid, corrosive, n.o.s.”

Section 172.101 (c)(1 0)(i)(F) states that a mixture or solution not identified specifically by name, comprised of a hazardous material identified in the Hazardous Materials Table (§ 172.101; HMT) by technical name and a non-hazardous material, shall be described using the proper shipping name of the hazardous material and the qualifying word  “mixtures” or : “solutions” as appropriate, unless the material can be appropriately described by a shipping name that describes its intended application.  It was the intent of this section to allow a material that is a mixture of a hazardous material that is identified by name in the HMT and a non-hazardous material, to be identified by a shipping name that describes its intended application or by the proper shipping name of the hazardous material and the appropriate qualifying word.  It was not the intent of § 172.101 (c)(10)(i)(F) to require such a material to be described under the materials application name.  Therefore, the previous opinion stated in our letter dated September 8, 1999 (Reference Number 99-0219) remains valid.  We will attempt to clarify this section in a future rule making.

In addition, the HMR do not limit a material to the selection of only one proper shipping name.  The HMR state that for a material not specifically identified by name in the HMT that it must be described by the shipping name that “most appropriately describes”  the material.  In some cases, more than one shipping name could “most appropriately describe” a material.  In those instances, a shipper has the discretion to decide what shipping name to use.

I hope this information is helpful.



Edward T. Mazzullo
Director, Office of Hazardous
Materials Standards



Regulation Sections

Section Subject
172.101 Purpose and use of hazardous materials table