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Interpretation Response #03-0245 ([HMT Associates, L.L.C.] [Mr. E. A. Altemos])

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

Interpretation Response Details

Response Publish Date:

Company Name: HMT Associates, L.L.C.

Individual Name: Mr. E. A. Altemos

Location State: VA Country: US

View the Interpretation Document

Response text:

Nov 12, 2003


Mr. E. A. Altemos               Ref. No. 03-0245
HMT Associates, L.L.C.
603 King Street, Suite 300
Alexandria, VA 22314

Dear Mr. Altemos:

This is in response to your letter dated October 3, 2003 and subsequent telephone conversation with Ben Supko concerning the requirements for desensitized explosives under the Hazardous Materials Regulations (HMR; 49 CPR Parts 171-180). Specifically, you ask if the Hazardous Materials Table (HMT: § 172.101) entry "Trinitrophenol, wetted with not less than 30 percent water, by mass" (UN1344) applies to trinitrophenol and water mixed with additional hazardous or nonhazardous materials.

The answer is no. After speaking with Dr. Charles Ke, Office of Hazardous Materials Technology, we have confirmed that the proper shipping name "Trinitrophenol, wetted" applies to trinitrophenol mixed with not less than 30 percent water, by mass and no other materials hazardous or otherwise. If you intend to ship trinitrophenol and water mixed with additional materials then you must receive authorization by the Associate Administrator via an exemption or approval.

I hope this satisfies your request.



Susan Gorsky
Senior Transportation Regulations Specialist
Office of Hazardous Materials Standards

Regulation Sections

Section Subject
172.101 Purpose and use of hazardous materials table