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Interpretation Response #04-0122 ([Wallace & Scott, I.I.P] [Mr. H. Pierce Scott])

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

Interpretation Response Details

Response Publish Date:

Company Name: Wallace & Scott, I.I.P

Individual Name: Mr. H. Pierce Scott

Location State: GA Country: US

View the Interpretation Document

Response text:

Jun 23, 2004


Mr. H. Pierce Scott                Reference No. 04-0122
Wallace & Scott, I.I.P.
Attorneys at Law
3547 N. Crossing Circle
Valdosta, Georgia 31604-2157

Dear Mr. Scott:

This responds to your letter dated April 29, 2007, regarding classification of your client’s product “Clo White” bleach containing 5.25% hypochlorite solution, under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180.

Your client, Dollar General Corporation, is involved in the shipment of household bleach manufactured by CloWbite Company (“CloWhite”) in the year 2000. CloWhite went out of business in 2001, and was purchased at that time by KIK International, Inc. (“KIK”). Based on the documentation you enclosed, you asked for confirmation of your understanding that CloWhite bleach containing 5.25% sodium hypochlorite solution manufactured during 2000 is not “corrosive”, as defined under the HMR.

Based on the information you provided, it is this Office’s opinion that the “CloWhite” bleach manufactured in 2000 and containing 5.25% hypochlorite does not meet the definition or criteria in § 173.136 and 173.137 for a corrosive material. Thus, your client’s product containing 5.25% sodium hypochlorite solution would not be subject to the HMR for purposes of transportation in commerce.

I hope this satisfies your inquiry. If we can be of further assistance, please contact us.



John A. Gale
Chief, Standards Development
Office of Hazardous Materials Standards


Regulation Sections

Section Subject
172.101 Purpose and use of hazardous materials table