Interpretation Response #05-0032 ([Seacon Corporation] [Mr. Sean E. Condren])

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

Interpretation Response Details

Response Publish Date: 03/10/2005

Company Name: Seacon Corporation

Individual Name: Mr. Sean E. Condren

Location State: NC Country: US

View the Interpretation Document

Response text:

Mar 10, 2005

Mr. Sean E. Condren                 Reference No. 05-0032
President
Seacon Corporation
525 N. Tryon St., Suite 1600
Charlotte, NC 28202

Dear Mr. Condren:

This is in response to your request for clarification concerning the applicability of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) to the domestic transportation of”Azodicarbonamide,” UN3242. Specifically, you ask whether your material is regulated under the HMR. You state that the material has a self-accelerated decomposition temperature (SADT) above 75 °C and does not meet the definition of Division 4.1 or any other hazard class under the HMR.

In the § 172.101 Hazardous Materials Table, “Azodicarbonamide,” UN3242 is assigned Special Provision 38, which states that when the SADT of the technically pure substance is higher than 75 °C, the substance and formulations derived from it are not self-reactive, and provided the material does not meet any other hazard class, it is not regulated under the HMR. If these conditions are met, you are correct that your azodicarbonamide is not regulated under the HMR and, therefore, is not regulated for domestic transportation. However, as also contained in Special Provision 38, if the azodicarbonamide shows a violent effect during 1:esting involving heating under confinement, the material is regulated for domestic transportation and must be packaged in accordance with Packing Method 0P6 in § 173 .225 and meet the labeling requirements in Special Provision 53.

I hope this information is helpful. Please contact this office if we can be of further assistance.

Sincerely,

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

172.101

Regulation Sections