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Interpretation Response #05-0214 ([Supresta Built-In Defense] [Dr. Andy Wang])

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

Interpretation Response Details

Response Publish Date:

Company Name: Supresta Built-In Defense

Individual Name: Dr. Andy Wang

Location State: NY Country: US

View the Interpretation Document

Response text:

Nov 21, 2005

 

Dr. Andy Wang                     Ref. No. 05-0214
Supresta Built-In Defense
Ardsley Park
420 Saw Mill River Road
Ardsley, NY 10502

Dear Dr. Wang:

This is in response to your September 12, 2005, letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 100-185). Specifically, you request confirmation from this Office that a product that contains 1-4% triphenylphophate in combination with tert-butylated triphenylphosphates is neither a marine pollutant nor a severe marine pollutant and therefore, is not subject to the HMR.

Under § 173.22, it is the shipper’s responsibility to properly classify and describe a hazardous material. This Office does not normally perform that function. However,
based on the information submitted, it is the opinion of this Office that a triphenyl phosphate/tert-butylate triphenyl phosphates mixture containing 1% to 4% triphenyl phosphates is not a marine pollutant nor a severe marine pollutant according to Appendix B in § 172.101. Therefore, provided your product does not otherwise meet the definition of a hazardous material (§ 171.8), it is not subject to the HMR.

Sincerely,

 

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

172.101

Regulation Sections

Section Subject
172.101 Purpose and use of hazardous materials table