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Interpretation Response #05-0317 ([Director, Manufacturing] [Jerry Jones, Ph.D.])

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

Interpretation Response Details

Response Publish Date:

Company Name: Director, Manufacturing

Individual Name: Jerry Jones, Ph.D.

Location State: MA Country: US

View the Interpretation Document

Response text:

Jan 30, 2006


Jerry Jones, Ph.D.                        Reference No. 05-0317
Director, Manufacturing/
Organic Synthesis
Chemic Laboratories, Inc.
480 Neponset Street Bldg. 7
Canton, MA 02021

Dear Dr. Jones:

This responds to your letter dated December 19, 2005, regarding the classification of your company’s product under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask whether the classification of your product would change under the HMR after additional constituents are added to its original formulation.

The original product formulation is described as “Resin solution, flammable, Class 3, UN1866, PG II,” a solution containing approximately 50% ethanol, to which you add five additional non-hazardous constituents. You state that the specific gravity, vapor pressure, and flash point of the original formulation is not altered when the additional constituents are added and that the new formulation is compatible with its original packaging. You intend to re ship the new formulation in its original packaging.

In accordance with § 173.22 of the HMR, it is the shipper’s responsibility to properly class and describe a hazardous material for transportation. This Office does not perform that function. However, it is our opinion that the altered formulation of the product your company receives does not change the original classification of that product and therefore, it may continue to be described as “Resin solution, flammable, Class 3, UN1866, PG II.”

I trust this satisfies your inquiry. Please contact us if we can be of further assistance.



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


Regulation Sections

Section Subject
172.101 Purpose and use of hazardous materials table