Interpretation Response #03-0321 ([Fisher Scientific Company, LLC] [Mr. John G. Mayfield])

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

Interpretation Response Details

Response Publish Date: 01/30/2004

Company Name: Fisher Scientific Company, LLC

Individual Name: Mr. John G. Mayfield

Location State: PA Country: US

View the Interpretation Document

Response text:

Jan 30, 2004

Mr. John G. Mayfield                Reference No. 03-0321
Manager, Dangerous Goods Transportation
Fisher Scientific Company, LLC
2000 Park Lane
Pittsburgh, PA 15275-1126

Dear Mr. Mayfield:

This is in response to your letter dated December 17, 2003 requesting clarification on the classification of Bouin’s Solution under the Hazardous Materials Regulations (HMR: 49 CFR Parts 171-180).  Specifically, you would like a letter confirming your conclusions that a mixture consisting of 1.5% picric acid, 9% acetic acid, 19% formaldehyde, < 1% coloring agent, and approximately 79% water should be classified as "Corrosive liquid, acidic, organic, n.o.s. (formaldehyde, acetic acid), 8, UN3266, III.”

Under § 173.22 of the HMR, it is the shipper's responsibility to properly classify a hazardous material.  This office generally does not perform this function.  The definition of a corrosive material is found in § 173.136 of the HMR and procedures for packing group selection are found in § 173.137. Assuming that you have reviewed those sections and determined that your Bouin’s Solution meets the definition of a corrosive material in packing group III and is assigned to the Corrosive liquid hazard class then the proper shipping name “Corrosive liquid, acidic, organic, n.o.s. (formaldehyde, acetic acid)” would be appropriate. However, the identification number that you provided in your letter, UN3266, is not consistent with the proper shipping name that you selected.  LTN3266 is the identification number for the proper shipping name “Corrosive liquid, basic, inorganic, n.o.s.”. If your conclusions are accurate, then it is our opinion that the actual description would be "Corrosive liquid, acidic, organic, n.o.s. (formaldehyde, acetic acid), 8, UN3265, III.”

If you determine that a particular mixture of Bouin’s Solution does not meet the definition of a corrosive material or any other hazard class, but it does present a risk during transportation, specifically air transportation, then it is our opinion that the basic description “Aviation regulated liquid, n.o.s. (formaldehyde), 9, UN3334, III would be acceptable.  However, if the acetic acid or picric acid contribute in any way to the hazards of the material they may be required to be included in basic description as part of the technical name (i.e., Aviation regulated liquid, n.o.s. (formaldehyde, acetic acid), 9, UN3334, III or Aviation regulated liquid, n.o.s. (formaldehyde, picric acid), 9, UN3334, III).

I hope this satisfies your request.

Sincerely,

Susan Gorsky
Senior Transportation Regulations Specialist
Office of Hazardous Materials Standards

173.136

Regulation Sections