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Interpretation Response #06-0242 ([Solvay Chemicals, Inc.] [Dr. Marc A. Feldman, CQM/OE ])

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

Interpretation Response Details

Response Publish Date:

Company Name: Solvay Chemicals, Inc.

Individual Name: Dr. Marc A. Feldman, CQM/OE 

Location State: TX Country: US

View the Interpretation Document

Response text:

Dec 7, 2006

 

Dr. Marc A. Feldman, CQM/OE                 Reference 06-0242
Regulatory Affairs Manager
Solvay Chemicals, Inc.
P.O. Box  27328
Houston, TX 77227-7328

Dear Dr. Feldman:

This is in response to your request for clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) regarding the use of the most appropriate proper shipping name for your material. Specifically, you state that Solvay Chemicals manufactures ammonium fluoride solid dissolved in water at various strengths and transports the material domestically and internationally. Based on your interpretation of the HMR, you believe that “Ammonium fluoride solution,” UN2505 is the most appropriate proper shipping name; however, you state that the International Civil Aviation Organization (ICAO) Technical Instructions, the International Maritime Dangerous Goods (IMDG) Code and the International Air Transport Association (IATA) Dangerous Goods Regulations require the proper shipping name “Toxic liquid, inorganic, n.o.s. (ammonium fluoride solution),” UN3287 for your material. You ask whether, under the HMR, the proper shipping name “Toxic liquid, inorganic, n.o.s. (ammonium fluoride solution)” may be used when transporting this material domestically only.

In assigning a proper shipping name, you must select the shipping name most appropriate to the material being transported. You are correct that under the HMR your ma must be transported using the proper shipping name “Ammonium fluoride solution,” UN 2505 in accordance with the provisions of § 172.101(c)(10). Section 172. 101(i)(4) provides a table for use when the packaging sections specified for a hazardous material specifically named in the Hazardous Materials Table are not applicable to the form of the material being transported (e.g., the packaging specified is for a solid material and the material being offered for transportation is a liquid). Section 172.101(c)(10) and (i)(4) apply to all modes of transportation.

Under the HMR, you may use the proper shipping name “Toxic liquid, inorganic, n.o.s. (ammonium fluoride solution),” UN3287 in accordance with the International Civil Aviation Organizaton Technical Instructions for the Safe Transport of Dangerous Goods by Air and the International Maritime Dangerous Goods Code only when your material is transported by aircraft and by motor vehicle either before or after being transported by aircraft or when all or part of the transportation is by vessel (see § 171.11 and 171.12). You may not use the proper shipping name “Toxic liquid, inorganic, n.o.s. (ammonium fluoride solution),” UN3287 for transportation within the United States if no p art of the transportation is by aircraft or vessel.

I hope this information is helpful. Please contact this office if you need additional information.

Sincerely,

 

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

172.101

Regulation Sections

Section Subject
172.101 Purpose and use of hazardous materials table