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

Interpretation Response #03-0243 ([Quaker Chemical Corporation] [Ms. Kathryn F. Strang, CHMM])

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

Interpretation Response Details

Response Publish Date:

Company Name: Quaker Chemical Corporation

Individual Name: Ms. Kathryn F. Strang, CHMM

Location State: PA Country: US

View the Interpretation Document

Response text:

Nov 4, 2003


Ms. Kathryn F. Strang, CHMM               Ref. No. 03-0243
Manager, Regulatory & Environmental Affairs
Quaker Chemical Corporation
One Quaker Park
901 Hector Street
Conshohocken, PA 19428-0809

Dear Ms. Strang:

This responds to your September 29, 2003, letter requesting clarification on the proper classification of a liquid containing water and sodium nitrite, as well as several other non-hazardous materials under the Hazardous Materials Regulations (ffivIR.; 49 CFRParts 171¬180). Specifically, you ask whether you should classify the material as "Oxidizing Liquid, n.o.s., 5.111 or as an "Environmentally Hazardous Substance, Liquid, n.o.s., 9".

Section 173.22 requires the shipper to properly class and describe the hazardous material in accordance with the HMR. This Office does not perform that function. If the sodium nitrite mixture you describe meets the defining criteria in Part 173 for a Division 5.1 Oxidizer, you may describe the material as "Sodium nitrite solution, UN 1500, PG III" or "Oxidizing liquid, n.o.s.(sodium nitrite), 5.1, UN 3139, PG I, II, or III, "as appropriate." In addition, sodium nitrite is listed as a hazardous substance in Appendix A to § 172.10 1, List of Environmentally Hazardous Substances and Reportable Quantities, with a reportable quantity of 100 pounds. If the quantity of material being transported in one package meets or exceeds the reportable quantity for sodium nitrite, the letters "RQ" must be included either before or after the basic description.

I hope this answers your inquiry.



Susan Gorsky
Senior Transportation Regulations Specialist
Office of Hazardous Materials Standards

Regulation Sections

Section Subject
172.101 Purpose and use of hazardous materials table