Interpretation Response #01-0250 ([Aristech Chemical Corporation] [Mr. Mike Alston])

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

Interpretation Response Details

Response Publish Date: 10/16/2001

Company Name: Aristech Chemical Corporation

Individual Name: Mr. Mike Alston

Location State: PA Country: US

View the Interpretation Document

Response text:

October 16, 2001

Mr. Mike Alston                             Reference No: 01-0250

Manager

Regulatory Compliance-Chemicals

Aristech Chemical Corporation

200 Neville Road

Pittsburgh, PA 15225

Dear Mr. Alston:

This is in response to your letter concerning the proper shipping name for phthalic anhydride with less than .05 % maleic anhydride.  Specifically you asked whether you should describe the material as "Elevated temperature liquid, n.o.s., (phthalic anhydride), 9, UN 3257, III, RQ" or "Hot Environmentally hazardous substances, n.o.s., (phthalic anhydride), 9, UN 3082, III, RQ." The phthalic anhydride has a reportable quantity of 5000 pounds and is shipped at a temperature of 280° F, which is below the material's flashpoint of 305° F.

Either shipping name may be used.  The Hazardous Materials Regulations (HMR; 49 CFR parts

171-180) state that a material not specifically identified by name in the Hazardous Materials

Table must be described by the shipping name that "most appropriately describes" the material

(see § 172.101(c)(12)(ii)).  In some cases, more than one shipping name could  "most appropriately describe" a material. In those instances, a shipper has the discretion to decide which shipping name to use.

I hope this information is helpful.

Sincerely,

John A Gale

Transportation Regulations Specialist.

Office of Hazardous Materials Standards

173.140

Regulation Sections