Interpretation Response #03-0288 ([Huntsman Corporation] [Mr. Philip Abraham])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Huntsman Corporation
Individual Name: Mr. Philip Abraham
Location State: TX Country: US
View the Interpretation Document
Response text:
Feb 25, 2005
Mr. Philip Abraham Reference No. 03-0288
Huntsman Corporation
10003 Woodloch Forest Drive
Woodlands, TX 77380
Dear Mr. Abraham:
This responds to your November 6, 2003, letter requesting clarification on the hazard class of your product under the Hazardous Materials Regulations (HMR; 49 CFRParts 171-180). Specifically, you request verification that the hazard class assigned to your product "Jeffamine D-2000, polyoxypropylenediamine" is correct.
According to your letter and enclosed test data, your product is currently described as "Corrosive liquids, toxic, n.o.s.(polyoxypropylenediamine), 8, UN 2922, PG ill" with a . subsidiary Division 6.1 toxic hazard for oral toxicity. You state that based on two separate tests, your product meets the defining criteria in the HMR for Class 8 corrosive liquid as the primary hazard class with a subsidiary Division 6.1 toxic hazard for oral toxicity. However, using your Huntsman test data, your competitor has classed the same product as a Class 8 corrosive liquid with no subsidiary Division 6.1 toxic hazard for oral toxicity. You request verification on the correct hazard class.
Under § 173.22, it is the shipper's responsibility to properly class and describe a hazardous material for shipment. This Office does not ordinarily perform that function. However, based on the information and test data provided in your letter, it is the opinion of this Office that your product is properly classed as a Class 8 corrosive liquid at the packing group ill level with a subsidiary Division 6.1 toxic hazard for oral toxicity.
I hope this answers your inquiry.
Sincerely,
Susan Gorsky
Senior Transportation Regulations Specialist
Office of Hazardous Materials Standards
Regulation Sections
| Section | Subject |
|---|---|
| 173.132 | Class 6, Division 6.1-Definitions |