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Interpretation Response #05-0079 ([Arkema, Inc.] [Ms. Christina M. Kurtz])

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

Interpretation Response Details

Response Publish Date:

Company Name: Arkema, Inc.

Individual Name: Ms. Christina M. Kurtz

Location State: PA Country: US

View the Interpretation Document

Response text:

May 12, 2005


Ms. Christina M. Kurtz                     Reference No. 05-0079
Supervisor-Regulations and Packaging
Arkema, Inc.
2000 Market Street
Philadelphia, PA 19103

Dear Ms. Kurtz:

This responds to your March 30, 2005 letter requesting clarification on the proper shipping name for “Acrylic Acid  $ 99%” that also meets the definition of a Division 6.1, PG III material under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171- 180). Specifically, you ask whether you should use the proper shipping name specifically identified in the Hazardous Materials Table (HMT) in § 172.101 for Acrylic Acid or a generic entry based on the hazard class of the material.

According to your letter, you describe your material on shipping papers as “Acrylic Acid, stabilized, 8, (3, 6.1), UN 2218, PG II.” Your understanding is correct. A generic “N.O.S” description is used for multiple hazard materials only when the material is not specifically identified in the HMT.

I hope this answers your inquiry.



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


Regulation Sections

Section Subject
172.101 Purpose and use of hazardous materials table
172.202 Description of hazardous material on shipping papers
172.402 Additional labeling requirements