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Interpretation Response #03-0302 ([Anitox Corporation] [Ms. Linda Isbill])

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

Interpretation Response Details

Response Publish Date:

Company Name: Anitox Corporation

Individual Name: Ms. Linda Isbill

Location State: GA Country: US

View the Interpretation Document

Response text:

Jan 6, 2004


Ms. Linda Isbill                Reference No. 03-0302
Anitox Corporation
1055 Progress Circle
Lawrenceville, GA  30043

Dear Ms. Isbill:

This is in response to your letter dated November 21, 2003 and telephone conversation with a member of my staff.  Specifically, you ask whether propionic acid with a flashpoint of 53EC should be described as “Propionic acid, 8, UN1848, PG III” or “Flammable liquids, corrosive, n.o.s. (Propionic acid), 3, 8, UN2924, PG III.”

Section 172.101(c)(12)(i). states that if it is specifically determined that a material meets the definition of a hazard class, packing group or hazard zone, other than the class, packing group or hazard zone shown in association with the proper shipping name, or does not meet the defining criteria for a subsidiary hazard shown in Column 6 of the Table, the 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.  Under § 173.2a, Class 3, Packing Group III takes precedence over Class 8, Packing Group III.  Therefore, the proper shipping description for propionic acid with a flash point of 53E C is “Flammable liquids, corrosive, n.o.s. (Propionic acid), 3, 8, UN2924, PG III.”

I hope this satisfies your request.



John A. Gale

Transportation Regulations Specialist
Office of Hazardous Materials Standards


Regulation Sections

Section Subject
172.101 Purpose and use of hazardous materials table