USA Banner

Official US Government Icon

Official websites use .gov
A .gov website belongs to an official government organization in the United States.

Secure Site Icon

Secure .gov websites use HTTPS
A lock ( ) or https:// means you’ve safely connected to the .gov website. Share sensitive information only on official, secure websites.

U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #03-0002 ([Sunoco, Inc.] [Mr. Michael Alston])

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

Interpretation Response Details

Response Publish Date:

Company Name: Sunoco, Inc.

Individual Name: Mr. Michael Alston

Location State: PA Country: US

View the Interpretation Document

Response text:

Jul 1, 2003


Mr. Michael Alston                Reference No. 03-0002
Manager-Regulatory Compliance
Sunoco, Inc.
200 Neville Road
Pittsburgh, PA 15225

Dear Mr. Alston:

This is in response to your letter regarding the description of “waste organic peroxide, Type F, (cumene hydroperoxide) 5.2, UN3109, PG II” under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).

Your letter states that the cumene hydroperoxide has a concentrated mass of £ 90 % and a diluent mass of ³
10 % and the cumene hydroperoxide liquid is totally absorbed in a filter substance that is compatible with the product.  You ask whether this material should be described on the shipping paper as a “liquid” or a “solid”.  In your opinion, “liquid” better describes the material even though the liquid is totally absorbed in the filter substance.

Based on the information contained in your letter, it is our opinion that the material should be described as a “solid” if no free flowing liquid is Visible surrounding the filter substance.  Therefore, for a waste material, a shipping name that appropriately describes the material is “Waste organic peroxide, solid, type F, (filter cartridges containing absorbed cumene hydroperoxide), 5.2, UN3110, PG II.”

I hope this satisfies your request.



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


Regulation Sections

Section Subject
172.101 Purpose and use of hazardous materials table