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Interpretation Response #03-0114 ([Dupont Global Services Business] [Mr. Randolph Martin])

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

Interpretation Response Details

Response Publish Date:

Company Name: Dupont Global Services Business

Individual Name: Mr. Randolph Martin

Location State: DE Country: US

View the Interpretation Document

Response text:

June 20, 2003


Mr. Randolph Martin               Ref. No. 03-0114
Dupont Global Services Business
1007 Market Street, Room D-5100
Wilmington, DE 19898

Dear Mr. Martin:

This responds to your November 18, 2002 letter requesting clarification on the proper shipping name to be marked on your tank cars under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). We apologize for the delay in responding and hope it has not caused you any inconvenience.' Specifically, you ask if it is permissible to mark the proper shipping name, "Sulfuric Acid" for both your "Sulfuric acid, UN 183011 and "Sulfuric acid, spent, UN 183211 materials carried in the same fleet of rail tank cars.

According to your letter, you supply your customer with tank cars of "Sulfuric acid, UN183011". The customer then recovers and returns to you "Sulfuric acid, spent, UN 1832 II. In order to avoid changing the marking every time the tank car switches from "Sulfuric acid, UN 1830" to "Sulfuric acid, spent, UN 1832" and back again, you want to use "Sulfuric acid" to describe both materials. It is your understanding that it is permissible to use the proper shipping name, "Sulfuric acid" for both materials under the HMR.

Based on the information provided in your letter, it is the opinion of this Office that use of the words "Sulfuric acid" marked on the tank car to describe both materials is permissible. However, the proper UN identification number must be displayed on the tank car and the shipping papers must show the proper shipping description and UN identification number for the material being shipped.

I hope this answers your inquiry.



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

Regulation Sections

Section Subject
172.101 Purpose and use of hazardous materials table