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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #06-0122 ([Minnesota Department of Transportation] [Mr. Michael Ritchie])

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

Interpretation Response Details

Response Publish Date:

Company Name: Minnesota Department of Transportation

Individual Name: Mr. Michael Ritchie

Location State: MN Country: US

View the Interpretation Document

Response text:

Jul 31, 2006


Mr. Michael Ritchie                 Reference No. 06-0122
Minnesota Department of Transportation
Office of Freight and Commercial
  Vehicle Operations
Mail Stop 460, Room 121
395 John Ireland Blvd.
St. Paul, MN 55155

Dear Mr. Ritchie:

This is in response to your letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) regarding proper shipping names for diesel fuel and fuel oils mixed with vegetable and animal oils, and gasoline mixed with denatured ethanol. The first product (B 2) is 98% fuel oil/diesel fuel blended with 2% vegetable and animal oils. The second product (B-20) is 80% fuel oil blended with 20% vegetable and animal oils. The third product is gasoline blended with at least 10% denatured ethanol. You state that data indicates the fuel oils blended with vegetable and animal oils have flash points meeting Class 3 (flammable) or combustible liquid definitions under the HMR. You also state that the shipping papers for these materials do not indicate that the material is mixed, rather, they show the materials listed separately. You ask which shipping names are most appropriate for these products.

A hazardous material mixed with a non-hazardous material must be described using the proper shipping name of the hazardous material and the qualifying word “mixture” or “solution,” as appropriate, unless any of the provisions in § 172.l0l(c)(l0)(i) (A) through (F) apply. Therefore, the most appropriate proper shipping names for the first product (B-2) are “Diesel fuel solution,” NA1993, “Diesel fuel solution,” UN1202, or ‘Fuel oil solution,” NA 1993, as appropriate. The most appropriate proper shipping names for the second product (B-20) are “Fuel oil solution,” NA 1993 or “Flammable liquid, n.o.s. (fuel oil solution),” UN1 993, as appropriate. A material that is a mixture or solution must be indicated on the shipping paper with its appropriate proper shipping name and may not have its constituents or commercial names listed separately in lieu of the proper shipping name. Such information may, however, be indicated following the basic description.

Currently, the most appropriate proper shipping name for gasoline mixed with riot more than 10% alcohol is “Gasohol,” NA1203 or “Flammable liquid, n.o.s. (contains gasoline with 10% denatured alcohol),” UN1993. The proper shipping name “Gasoline,” UN1203 would be appropriately assigned to gasoline that is not mixed with other hazardous materials.

I hope this information is helpful. Please contact this office should you have additional questions.



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

172.101 (c)(10)(i)(A)

Regulation Sections

Section Subject
172.101 Purpose and use of hazardous materials table