Interpretation Response #01-0095 ([Atlantic Research Corporation] [Mr. Aaron Greso])

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

Interpretation Response Details

Response Publish Date: 05/22/2001

Company Name: Atlantic Research Corporation

Individual Name: Mr. Aaron Greso

Country: VA

View the Interpretation Document

Response text:

MAY 22, 2001

Mr. Aaron Greso                      Ref. No. 01-0095
Atlantic Research Corporation

5945 Wellington Road
Gainesville, Virginia 20166-1699

Dear Mr. Greso:

This responds to your April 17, 2001 letter requesting clarification on the correct classification of your mixture under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask for the correct classification of a mixture of silver nitrate and potassium nitrate, each of which is classed as a Division 5.1 material.

Your understanding that a "new" material must be tested as a Class 1 explosive using the "Card Gap"
test under the UN Manual of Tests and Criteria is incorrect. Such a test is required only where other information indicates the material could have explosive properties. Under the HMR, it is the shipper's responsibility to determine the hazard class of the material to be transported. This Office does not perform that function. In making this determination, you must consider the characteristics of the entire mixture rather than its individual components. Based on the test results and information provided in your letter, it is the opinion of this Office that the mixture of silver nitrate and potassium nitrate should be classed according to the Division 5.1 packing group criteria in § 173.127 of the HMR.

I hope this answers your inquiry.

Sincerely,

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

172.101

Regulation Sections