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.
Sincerely,
John A. Gale
Chief, standards Development
Office of Hazardous Materials Standards
172.101, 173.22