Interpretation Response #06-0244 ([Fisher Scientific International, Inc.] [Mr. Gene Sanders])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Fisher Scientific
International, Inc.
Individual Name: Mr. Gene Sanders
Location State: PA Country: US
View the Interpretation Document
Response text:
Mr. Gene Sanders Reference No. 06-0244
Dangerous Goods
Transportation Specialist
Fisher Scientific
International, Inc.
2000 Park Lane
Pittsburgh, PA 15275
Dear Mr. Sanders:
This responds to your letter requesting clarification on the classification of Hollande’s Solution under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask for confirmation that you have properly classified a solution consisting of < 2.38% picric acid, 1.2% methyl alcohol, 1.0-1.5% acetic acid, 3.14% formaldehyde, 2.0-2.5% copper diacetate monohydrate, and > 90% water. Based on PH value (3.48) and the minimal amount of picric acid in Hollande’s Solution (< 2.38%) you intend to describe it as “UN3265, Corrosive liquid, acidic, organic, n.o.s. (Formaldehyde, Picric acid), 8, III.” In addition, you enclosed with your request copies of two previously issued interpretations that would appear to support your decision.
Although the entry in the § 172.101 Hazardous Materials Table (HMT) for Picric acid (Trinitrophenol, wetted) does not specify a lower limit for the concentration of picric acid in solution, we agree with your conclusion that Hollande’s Solution should not be described as a desensitized explosive of Hazard Class 3 or Division 4.l. Therefore, we agree with your decision to describe Hollande’s Solution as “UN3265, Corrosive liquid, acidic, organic, n.os. (Formaldehyde, Picric acid), 8, III.”
I trust this satisfies your inquiry. Please contact us if we can be of further assistance.
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 |