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Interpretation Response #02-0032 ([Elite Consumer Products] [Mark Chevrier])

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

Interpretation Response Details

Response Publish Date:

Company Name: Elite Consumer Products

Individual Name: Mark Chevrier

Location State: MA Country: US

View the Interpretation Document

Response text:

April 8, 2002

Mr. Mark Chevrier                   Reference No.: 02-0032
Director of Operations
Elite Consumer Products
203 West Avenue
Ludlow, MA 01056

Dear Mr. Chevrier:

This is in response to your letter inquiring whether a 6.0 wt% sodium hypochlorite solution is subject to the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  You submitted skin corrosivity test data for the material.  In a telephone conversation with a member of my staff, you stated that the material is packaged in one gallon containers.

Based on the data you provided, we agree that the 6% wt sodium hypochlorite solution is not corrosive to skin.  However, without test data for corrosivity on metals (steel and/or aluminum), we are unable to make the determination that your material does not meet the definition in § 173.136 of a corrosive material (Class 8) under the HMR.


Hattie L. Mitchell
Chief, Regulatory Review and Reinvention
Office of Hazardous Materials Standards


Regulation Sections

Section Subject
173.22 Shipper's responsibility