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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 #07-0101 ([Degussa Corporation] [Mr. John Foglio])

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

Interpretation Response Details

Response Publish Date:

Company Name: Degussa Corporation

Individual Name: Mr. John Foglio

Location State: NJ Country: US

View the Interpretation Document

Response text:

Jul 11, 2007

Mr. John Foglio                Reference No. 07-0101

Degussa Corporation

379 Interpace Parkway

Parsippany, New Jersey 07054-8042

Dear Mr. Foglio:

This is in response to your May 9, 2007 letter regarding the applicability of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) to the transportation of acetone cyanohydrin. Specifically, you request clarification of a previous letter of interpretation issued to you by this office on March 16, 2007 (Ref No.: 07-0046), which stated that the proper shipping name "Acetone cyanohydrin, stabilized" is not an appropriate proper shipping name for your material because the material does not meet the definition of an inhalation hazard. Based on the information you provided at that time, we recommended using the generic proper shipping name, "Toxic liquid, organic, n.o.s." In your follow-up request for interpretation you have added that the material is a nitrile with a dermal toxicity of 17 mg/kg. Based on the additional information, you ask if it is more appropriate to use the proper shipping description "UN 3276, Nitriles Toxic Liquid, n.o.s., 6.1, PG I."

As you are aware, it is the shipper's responsibility to properly class and describe a hazardous material. This office does not perform that function. However, based on the technical data you originally submitted and the additional information you provided in this follow-up letter, it is the opinion of this office that "Nitriles toxic liquid, n.o.s., 6.1, PG I" is a more appropriate proper shipping description for your material.

I hope this information is helpful. If you have further questions please do not hesitate to contact this office.


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