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Interpretation Response #03-0174 ([Woodside Inc.] [Andrew Woodside Ph.D.])

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

Interpretation Response Details

Response Publish Date:

Company Name: Woodside Inc.

Individual Name: Andrew Woodside Ph.D.

Location State: OK Country: US

View the Interpretation Document

Response text:

Jul 23, 2003


Andrew Woodside Ph.D.               Reference  No. 03-0174
Woodside Inc.
300  Hanna  Dr.
Ponca City, OK  74604

Dear Dr. Woodside,

This is in response to your July 16, 2003, letter regarding the applicability of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) to tricresyl phosphate, with less than 3 percent ortho isomer.

Under § 173.22, it is the shipper’s responsibility to properly classify a hazardous material.  Such determination are not required to be verified by this office.  However, “Tricresyl phosphate with more than 3 percent ortho isomer, 6.1, UN 2574, PG II” is not an appropriate proper shipping name if your product has less then 3 percent ortho isomer.  Section 172.101(c)(12)(i) states that a material shall be described by an appropriate proper shipping name listed in association with the correct hazard class, packing group, hazard zone, or subsidiary hazard for the material.  If your material does not meet the criteria of a Division 6.1 and does not meet any other hazard class, it is not subject to the HMR.

I hope this satisfies your request.



John A. Gale
Transportation Regulations Specialist
Office of Hazardous Materials Standards


Regulation Sections

Section Subject
173.22 Shipper's responsibility