Interpretation Response #00-0306 ([Chemtech Finishing System] [Ms. Stephanie Williams])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Chemtech Finishing System
Individual Name: Ms. Stephanie Williams
Location State: MI Country: US
View the Interpretation Document
Response text:
November 7, 2000
Ms. Stephanie Williams Ref. No. 00-0306
Regulatory Affairs Engineer
Chemtech Finishing System
23177 Commerce Drive
Farmington Hills, Michigan 48335
Dear Ms. Williams:
This responds to your letter, dated October 31, 2000, concerning transportation of lithium hydroxide under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if you may rename a technically pure shipment of lithium hydroxide as a lithium hydroxide mixture or a corrosive solid mixture, n.o.s., in order to protect a trade secret.
The answer is no. As defined in the HMR, a "mixture" means a material composed of more than one chemical compound or element (see § 171.8). Technically pure lithium hydroxide is not a mixture and may not be so described on a shipping paper. Further, generic shipping names, such as corrosive solid, n.o.s., are to be used only for hazardous materials not specifically listed by name in the Hazardous Materials Table. As your letter notes, lithium hydroxide, solid, is listed in Column (2) of the table. Thus, the shipping description for technically pure lithium hydroxide is: Lithium hydroxide, solid, 8, UN 2680, PG II.
I hope this information is helpful. If you have further questions, please do not hesitate to contact this office.
Sincerely,
Thomas G. Allan
Senior Transportation Regulations Specialist
Office of Hazardous Materials Standards
172.101
Regulation Sections
| Section | Subject |
|---|---|
| 172.101 | Purpose and use of hazardous materials table |