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Interpretation Response #04-0195 ([General Hydroponics] [Mr. Cal Herrmann ScD])

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

Interpretation Response Details

Response Publish Date:

Company Name: General Hydroponics

Individual Name: Mr. Cal Herrmann ScD

Location State: CA Country: US

View the Interpretation Document

Response text:

Jun 13, 2005


Mr. Cal Herrmann ScD                Reference No. 04-0195
Consulting Chemist
General Hydroponics
P.O. Box 1576
Sebastopol, CA 95473

Dear Mr. Cal Herrmann:

This responds to your December 15, 2004 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) for plant nutrient products that are sold for hydroponic plant growth. Specifically, you ask if the products described in your letter are subject to the HMR. You provide the following two product descriptions:

1)         Aqueous solution of inorganic minerals containing less than 10% Nitrates.

2)        Dry mixtures of inorganic minerals containing calcium nitrate and ammonium nitrate, with less than 10% ammonium nitrate and at least 12% water of crystallization.

In accordance with § 173.22 of the HMR, it is the shipper’s responsibility to determine the hazard class of a material offered for transportation in commerce. This office does not perform that function.

Special Provision 58 (see § 172.102) provides an exception for aqueous solutions of Division 5.1 inorganic solid nitrate substances when the concentration of the substances in solution at the minimum temperature encountered in transport is not greater than 80% of the saturation limit. Your product is not subject to the HMR if it meets Special Provision 58 and does not meet the definition of any other hazard class listed in § 173.2.

Special Provision 34 (see § 173.102) provides an exception for commercial grade calcium nitrate fertilizer, when consisting mainly of a double salt (calcium nitrate and ammonium nitrate) containing not more than 10 percent ammonium nitrate and at least 12 percent water of crystallization. Your product is not subject to the HMR if it meets Special provision 34 and does not meet the definition of an other hazard class listed in § 173.2.





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, 172.102

Regulation Sections

Section Subject
172.101 Purpose and use of hazardous materials table
172.102 Special provisions