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Interpretation Response #01-0266 ([ADCO Products, Inc.] [Daniel M. Dixon])

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

Interpretation Response Details

Response Publish Date:

Company Name: ADCO Products, Inc.

Individual Name: Daniel M. Dixon

Location State: MI Country: US

View the Interpretation Document

Response text:

January 30, 2002


Daniel M. Dixon, Jr.                         Reference No. 01-0266
Health, Safety and Environmental
ADCO Products, Inc.
P. 0. Box 457
Michigan Center, MI 49254

Dear Mr. Dixon:

This is in response to your October 3, 2001 letter concerning assignment of a hazardous material to a specific packing group under the Hazardous Material Regulations (HMR: 49 CFR Parts 171 ­180). Specifically, you ask how to properly reassign a flammable liquid adhesive from a Packing Group II  to a Packing Group III when the liquid is too thick to complete the ISO 2431 (1984) viscosity test in § 173.12 1 (b)(2)(i), preventing the comparison of its viscosity and flash point required in § 173.121 (b)(1)(iv).  I apologize for the delay in responding and any inconvenience this may have caused.

You state that the adhesive has a flashpoint of 18º F and a boiling point of 185º F, does not separate when tested, does not contain any substances with a Division 6.1 (poison) or Class 8 (corrosive) hazard class, and is placed in six one-gallon inner packagings inside one outer packaging.  You also state that the adhesive flows freely through an ISO standard cup until the cup is 50 to 75 percent full, then thickens while standing and does not flow freely for the remaining time required to complete the test.  You further state that extrapolation of the test results yields flow times over 100 seconds through the 6 mm orifice.

It is the shipper's responsibility to properly classify a hazardous material in accordance with § 173.22. This office does not perform that function.  However, based on the information you provided, it is our opinion that the test results you have already completed for the adhesive fulfill the intent of the viscosity test prescribed in § 173.121(b)(2)(i). No further calculations estimating product performance are necessary, and the adhesive meets the criteria to be assigned to Packing Group III as prescribed in § 173.12 1 (b)(1).

I hope this satisfies your request.



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


Regulation Sections

Section Subject
173.121 Class 3-Assignment of packing group