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 |