Interpretation Response #02-0048 ([Octel Starreon LLC.] [Ann MarieWilliams])

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

Interpretation Response Details

Response Publish Date: 04/18/2002

Company Name: Octel Starreon LLC.

Individual Name: Ann MarieWilliams

Location State: DE Country: US

View the Interpretation Document

Response text:

April 18, 2002

Ms. Ann Marie Williams                     Reference No. 02-0048
Regulatory Affairs Administrator
Octel Starreon LLC.
200 Executive Drive
Newark, Delaware 19702

Dear Ms. Williams:

This responds to your February 12, 2002 letter requesting clarification on the proper shipment of "motor fuel antiknock" that is transported to the United States under the International Maritime Dangerous Goods (IMDG) Code and the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  You state that the material is transported in a bulk packaging by vessel.  Your questions are paraphrased and answered below.

Q1. Is it permissible to leave the "Marine Pollutant" marking in place when the containers are shipped on-road?

A1. Yes.  It is permissible to leave the "Marine Pollutant" mark in place when the containers are shipped on-road.

Q2. In regard to the information required on the shipping papers, is the following appropriate?
"Motor fuel Antiknock Mixtures, 6.1, (3), UN 1649, PG I"
"RQ (Tetraethyl Lead, Ethylene Di-Bromide)"

A2. Hazardous materials transported under the IMDG Code are subject to the conditions and restrictions contained in 49 CFR 171.12. The words "Marine Pollutant" must be included on shipping documents.  See Chapter 5.4.1.1 of the IMDG Code and 49 CFR 172.203 (1)(2).  For example, a correct shipping description for your shipment would read "Motor fuel anti-knock mixtures, 6.1, 3, UN 1649, PG I, RQ (Tetraethyl lead, Ethylene dibromide), Marine Pollutant".

Q3. What is the proper way to include the Marine Pollutant components (Tetraethyl Lead and Ethylene Di-Bromide) in the above shipping information?

A3. The name of the component or components which make a material a marine pollutant must appear in parentheses in association with the basic description.  See 49 CFR 172.203(1)(1).

Q4. One of our products has the chemical name, 2,4-Dimethyl-6-Tert-Butylphenol.  Butylphenols were removed from the Marine Pollutants list.  However, Dimethyl Phenols remain on the Marine Pollutant list. Would D.O.T. consider this material to be a Dimethyl Phenol?

A4. No, 2, 4-Dimethyl-6-Tert-Butylphenol is not synonymous with Dimethylphenol. For your information, Dirnethylphenols, liquid or solid will be removed from the List of Marine Pollutants in Appendix B to § 172.101 in a rulemaking document in the near future.

I hope this answers your inquiry.

Sincerely,

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

172.202

Regulation Sections