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Interpretation Response #02-0129 ([Patton Boggs, L.L.P.] [Carolina L.Mederos])

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

Interpretation Response Details

Response Publish Date:

Company Name: Patton Boggs, L.L.P.

Individual Name: Carolina L.Mederos

Location State: DC Country: US

View the Interpretation Document

Response text:

February 21, 1997

Ms. Carolina L. Mederos                    Reference No.: 02-0129
Transportation Policy Consultant
Patton Boggs, L.L.P.
2550 M Street, N.W.
Washington, D.C.. 20037-1350

Dear Ms. Mederos:

This is in response to your letter to Alan 1. Roberts, Associate Administrator for Hazardous Materials Safety, dated January 17, 1997, concerning the proper classification of unbuffered lactic acid under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  In particular, you requested confirmation that a lactic acid product is not a corrosive material and, assuming no other potentially hazardous attributes, is not a hazardous material under the HMR.  The letter was sent via FAX transmission.

Based on the definition for "corrosive material" at 49 CFR 173.136, test criteria to determine the packing group of Class 8 material at 49 CFR 173.137, and test data and other information you submitted, it is our opinion that the lactic acid product, as tested, is not a corrosive material.  Furthermore, if the material does not meet the definition for any other hazard class, it would not be subject to the HMR.

If we can be of further assistance, please contact us.

Sincerely,

Edward T. Mazzullo
Director, Office of Hazardous Materials Standards

173.134

Regulation Sections

Section Subject
173.134 Class 6, Division 6.2-Definitions and exceptions