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Interpretation Response #01-0271 ([Electron Microscopy Sciences] [Mr. Carole J. McNamara])

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

Interpretation Response Details

Response Publish Date:

Company Name: Electron Microscopy Sciences

Individual Name: Mr. Carole J. McNamara

Location State: PA Country: US

View the Interpretation Document

Response text:

December 18, 2001


Mr. Carole J. McNamara                            Reference  No. 01-0271
Electron Microscopy Sciences
P.O. Box 251
Fort Washington, PA 19034

Dear Ms. McNamara:

This responds to your October 16, 2001 letter requesting clarification on the proper shipping name and hazard class of forrnaldehyde solution with less than 25% formaldehyde under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Specifically, you ask if the proper shipping name should be “Aviation regulated liquid, n.o.s.” for formaldehyde solutions with a variety of percentages of less than 25% formaldehyde.  Additionally, you ask if there is a concentration at which a formaldehyde solution would not be subject to the HMR.

It is the shipper's responsibility to properly class and describe a hazardous material in accordance with § 173.22. This Office does not normally perform that function.  However, it is the opinion of this Office that formaldehyde solutions with less than 10% formaldehyde mixed with non-hazardous materials do not meet the definition of a Class 9 hazardous material and, provided they do not meet any other hazard class, are not subject to the HMR.  Formaldehyde solutions with lO% to 25% formaldehyde are regulated as Class 9 hazardous materials when shipped by aircraft due to its noxious odor.  The preferred proper shipping name is “Aviation regulated liquid, n.o.s.” The entry “Aviation regulated liquid, n.o.s.” was added to the § 172.101 Hazardous Material Table in a final rule published March 5, 1999 (Docket HM-215C; 64 FR 10741) for alignment with the ICAO Technical Instructions and the UN Recommendations.

I hope this answers your inquiry.



Delmer F. Billings
Chief, Standards Development
Office of  Hazardous Materials Standards


Regulation Sections

Section Subject
173.22 Shipper's responsibility