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Interpretation Response #06-0091 ([Buckingham, Doolittle & Burroughs, LLP] [Mr. David J. Hrina ])

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

Interpretation Response Details

Response Publish Date:

Company Name: Buckingham, Doolittle & Burroughs, LLP

Individual Name: Mr. David J. Hrina 

Location State: OH Country: US

View the Interpretation Document

Response text:

May 23, 2006


Mr. David J. Hrina                 Reference No. 06-0091
Buckingham, Doolittle & Burroughs, LLP
50 S. Main Street P.O. Box 1500
Akron, OH 44309-1500

Dear Mr. Hrina:

This is in response to your April 12, 2006 letter regarding the applicability of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) to rubber chemicals.

Under § 173.22, it is the shipper’s responsibility to properly class and describe a hazardous material. Such determinations are not required to be verified by this Office. According to your letter, the chemicals, which are hazardous materials in their pure powder form, are offered for transportation in a polymerically sealed binder material. You state that when sealed in the binder material the materials are insoluble in water and do not meet any of the hazard class definitions in Part 173. If a material does not meet one or more hazard class criteria in Part 173, and is not a hazardous substance, hazardous waste, or marine pollutant, it is not subject to the HMR.

I hope this information is helpful. Please contact us if you require additional assistance.



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

172.101, 173.22

Regulation Sections

Section Subject
172.101 Purpose and use of hazardous materials table
173.22 Shipper's responsibility