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Interpretation Response #01-0046 ([Shell Chemicals] [Mr. David Mashinski])

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

Interpretation Response Details

Response Publish Date:

Company Name: Shell Chemicals

Individual Name: Mr. David Mashinski

Location State: TX Country: US

View the Interpretation Document

Response text:

JUL 23, 2001

Mr. David Mashinski                    Reference No. 01-0046
HSE-Advisor
Shell Chemicals
P.O. Box 2463
Houston, TX 77252-2463

Dear Mr. Mashinski:

This is in response to your inquiry concerning the proper shipping name for different commercial grades of xylene under the Hazardous Materials Regulations (49 CFR Parts 171-180).

You state that your company produces two commercial grades of xylene. The first grade is a xylene stream produced prior to the extraction of the ethylbenzene isomer. It contains all four isomers of ortho-para-, meta- xylenes and ethylbenzene and more specifically is composed of 80-90% xylenes (mixed isomers) and 10-20% ethylbenzene. The second grade is the stream following extraction of the ethylbenzene. You asked whether the most appropriate proper shipping name for the first grade would be "Xylenes," UN1307 or "Flammable liquids, nos (Xylenes, Ethylbenzene)," UN1993.

It is our opinion that both descriptions are acceptable. Various reference sources, including the American Society for Testing and Materials' Standard D843-97, "Standard Specification for Nitration Grade Xylene," recognize that various technical and commercial grades of Xylenes may contain ethylbenzene.

I hope this satisfies your request.

Sincerely,

 

Hattie L. Mitchell, Chief
  Regulatory Review and Reinvention
  Office of Hazardous Materials Standards

172.101

Regulation Sections