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Interpretation Response #04-0058 ([Sherwin Williams Environmental, Health, & Regulatory Services] [Ms. Sandra Basham])

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

Interpretation Response Details

Response Publish Date:

Company Name: Sherwin Williams Environmental, Health, & Regulatory Services

Individual Name: Ms. Sandra Basham

Location State: OH Country: US

View the Interpretation Document

Response text:

Aug 9, 2005


Ms. Sandra Basham                 Reference No. 04-0058

Director of Transportation

Corporate Regulatory Affairs

Sherwin Williams Environmental, Health, & Regulatory Services

101 West Prospect Avenue

Cleveland, OH 44115-1075

Dear Ms. Bashman:

This is in response to your letter dated March 10, 2004 and subsequent telephone conversation with a member of my staff regarding the determination of a proper shipping name for your paint removal product under the under Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). According to your letter and telephone conversation, your product is a mixture composed of 85% Methylene Chloride (Dichloromethane), 10% methanol, ammonium hydroxide solution, and other non-hazardous materials. In addition, you indicate that the material exhibits hazards of Class 3 Packing Group II, Class 8 Packing Group II, and Division 6.1, Packing Group III. Specifically, you ask whether it is more appropriate to describe your product as "Paint related material, 8, UN 3066, PG II," or "Corrosive liquid, toxic, n.o.s., 8, UN 2922, PG II."

In accordance with § 173.22, it is the shipper"s responsibility to properly classify a hazardous material and assign it a proper shipping name from the Hazardous Material Table (HMT; § 172.101). Section 172.101(c)(12)(iii) states that if a material meets the definition of more than one hazard class and is not specifically identified by name in the HMT, then the hazard class of the material must be determined using the precedence criteria specified in § 173 .2a. To properly class a mixture containing hazardous components, you must analyze and test the entire mixture to determine its hazard class and if it poses any subsidiary hazards. Please note that the mixture may or may not exhibit the hazards of one or all of its components.

According to the information you provided about this material, Class 3, Packing Group II, takes precedence, followed by Class 8, Packing Group II, then Division 6.1, Packing

Group III. Therefore, an appropriate shipping description is "Flammable liquid, toxic, corrosive, n.o.s., 3 (8, 6.1), UN 3286, PG II." The descriptions "Paint related material, 8, UN 3066, PG II," and "Corrosive liquid, toxic, n.o.s., 8, UN 2922, PG II" do not accurately identify the hazards of the material.




I hope this information is helpful. Please contact us if you require additional assistance.



John A. Gale

Chief, Standards Development

Office of Hazardous Materials Standards

172.101, 173.2a

Regulation Sections

Section Subject
172.101 Purpose and use of hazardous materials table
173.2a Classification of a material having more than one hazard