Interpretation Response #05-0140 ([Greenview Chemical Sales, Inc] [Ms. Susan Jackson])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Greenview Chemical Sales, Inc
Individual Name: Ms. Susan Jackson
Location State: IL Country: US
View the Interpretation Document
Response text:
Jun 24,2005
Ms. Susan Jackson Reference No. 05-0140
Greenview Chemical Sales, Inc.
3759 N. Ravenswood Avenue
Suite 222
Chicago, Illinois 60613
Dear Ms. Jackson:
This responds to your June 7, 2005, letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if the mixture described in your letter meets the definition of a “hazardous substance.” You provide the following information:
1) The product is transported in bags that weigh 2,200 lbs. each.
2) Each bag contains zinc sulfate heptahydrate (660 lbs. per bag), iron sulfate heptahydrate (660 lbs. per bag), and moisture (880 lbs. per bag).
The answer is no. A Hazardous substance is defined in § 171.8 as a material, including its mixtures and solutions, that is listed in Appendix A to § 172.101, and is in a quantity, in one package, that equals or exceeds the reportable quantity (RQ) for the material listed in Appendix A. Both zinc sulfate and ferrous sulfate (iron sulfate) are listed in Appendix A with an RQ of 1,000 pounds. The mixture you describe does not meet the definition of a hazardous substance as defined in § 171.8, because the amounts in each bag do not exceed the RQs for the materials.
Although your material doesn’t meet the definition of a hazardous substance, it must be shipped as a hazardous material if it meets the definition of a hazardous waste, marine pollutant or any hazard class listed in § 173.2.
I hope this information is helpful.
Sincerely,
John A. Gale
Chief, Standards Development
Office of Hazardous Materials Standards
172.101 Appendix A