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.
Sincerely,
Hattie L. Mitchell
Chief, Regulatory Review and Reinvention
Office of Hazardous Materials Standards
173.22
Regulation Sections
Section | Subject |
---|---|
173.22 | Shipper's responsibility |