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Interpretation Response #02-0125 ([3M Company] [Ray Duzynski])

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

Interpretation Response Details

Response Publish Date:

Company Name: 3M Company

Individual Name: Ray Duzynski

Location State: MN Country: US

View the Interpretation Document

Response text:

Sep 19, 2002

Mr. Ray Duzynski                 Reference No. 02-0125

3M Company

3M Center, Bldg. 225-5N-07

St. Paul, MN 55144-1000

Dear Mr. Duzynski:

This is in response to your inquiry dated April 3, 2002 regarding the selection of a proper shipping name.  Specifically, you ask that if a material contains a material that does not contribute to the primary or subsidiary hazard class of the material, does it need to be included in the determination of the proper shipping name.

If a material, that in certain concentrations meets the definition of a hazardous material, is being shipped in a concentration that the mixture no longer meets the hazard class associated with the material, the material is not a hazardous material for purposes of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Section 172.101(c)(10)(i) states that a mixture or solution not identified specifically by name, comprised of a hazardous material identified in the Hazardous Materials Table (HMT) by technical name and non-hazardous material, shall be described using the proper shipping name of the hazardous material and the qualifying word "mixture" or solution, as appropriate, Therefore, a mixture comprised of a hazardous material identified by technical name in the HMT and a non-hazardous material that does not contribute to the primary or subsidiary hazard class of the material shall be described by the technical name of the hazardous material.

I hope this satisfies your inquiry.


Edward T . Mazzullo

Director, Office of Hazardous Materials Standards


Regulation Sections

Section Subject
172.101 Purpose and use of hazardous materials table