Interpretation Response #00-0201 ([Regulatory Compliance Services] [Mr. Chris Corea])

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

Interpretation Response Details

Response Publish Date: 09/25/2000

Company Name: Regulatory Compliance Services

Individual Name: Mr. Chris Corea

Location State: OH Country: US

View the Interpretation Document

Response text:

September 25, 2000

Mr. Chris Corea                             Ref. No. 00-0201
Regulatory Compliance Services
6740 Huntley Road
Suite 203
Worthington, Ohio 43229

Dear Mr. Corea:

This is in response to your letter dated July 20, 2000, requesting clarification on the proper shipping name for denatured alcohol under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  In your letter you reference three shipping names: "Ethanol solutions, 3, UN1170," "Flammable liquids n.o.s., 3, UN1993," and "Alcohols, n.o.s., 3, UN1987." Specifically, you asked which shipping name is most appropriate for a denatured alcohol.

Under § 173.22, it is the shipper's responsibility to properly classify a hazardous material and assign it a proper shipping name from the Hazardous Materials Table (HMT).  For a material not specifically identified by name in the HMT, the HMR requires that the material 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.  However, it is the opinion of this Office that the shipping name "Ethanol solutions" most appropriately describes denatured alcohol.

I hope this satisfies your request.

Sincerely,

Delmer F. Billings
Chief, Standards Development
Office of Hazardous Materials Standards

172.101(c)

Regulation Sections