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Interpretation Response #01-0061 ([Glencore] [Mr. Michael O'Connell])

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

Interpretation Response Details

Response Publish Date:

Company Name: Glencore

Individual Name: Mr. Michael O'Connell

Location State: CT Country: US

View the Interpretation Document

Response text:

MAR 7, 2001


Mr. Michael O'Connell                      Ref. No. 01-0061
Three Stamford Plaza
301 Tresser Boulevard
Stamford, CT 06901-3244

Dear Mr. O'Connell:

This is in response your February 27, 2001 letter, regarding the applicability of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) to ferrosilicon, with 65 to 75 percent silicon.

Under § 173.22, it is the shipper's responsibility to properly classify a hazardous material. Such determinations are not required to be verified by this office. However, based on the test results you provided, it is our opinion that the ferrosilicon described in your letter does not meet the criteria of a Division 4.3 and provided it does not meet any other hazard class, is not subject to the HMR.

I hope this satisfies your request.



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


Regulation Sections

Section Subject
173.22 Shipper's responsibility