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Interpretation Response #04-0225 ([Shane Havoc Consulting, LLC] [Gregory Sutherland, Ph.D])

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

Interpretation Response Details

Response Publish Date:

Company Name: Shane Havoc Consulting, LLC

Individual Name: Gregory Sutherland, Ph.D

Location State: SC Country: US

View the Interpretation Document

Response text:

Oct 28, 2004


Gregory Sutherland, Ph.D.                 Reference No. 04-0225
Shane Havoc Consulting, LLC
1905 English Ivy Court
Mt. Pleasant, SC 29464

Dear Dr. Sutherland:

This is in response to your September 22, 2004 letter requesting clarification of the requirements for inclusion of a technical name for a hazardous material described as “Corrosive liquid, acidic, organic, n.o.s.” under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if “(contains organic acids)” is an acceptable technical name in accordance with § 172.203(k).

The answer is no. As defined in § 171.8 of the HMR, “technical name” means a recognized chemical name or microbiological name currently used in scientific and technical handbooks, journals, and texts. A chemical description is authorized for use as a technical name provided it readily identifies the general chemical group. Examples of acceptable generic chemical descriptions are “organic phosphate compounds” and “aqueous amino silane polymer.”

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



Hattie L. Mitchell
Chief, Regulatory Review and Reinvention
Office of Hazardous Materials Standards

171.8, 172.203(k)

Regulation Sections

Section Subject
171.8 Definitions and abbreviations
172.203 Additional description requirements