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Interpretation Response #08-0103 ([Anodamine, Inc.] [Mr. Paul R. Hattingh])

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

Interpretation Response Details

Response Publish Date:

Company Name: Anodamine, Inc.

Individual Name: Mr. Paul R. Hattingh

Location State: TX Country: US

View the Interpretation Document

Response text:

May 23, 2008



Mr. Paul R. Hattingh

Anodamine, Inc.

2590 Oakmont Drive, Suite 310

Round Rock, TX 78665

Ref. No.: 08-0103

Dear Mr. Hattingh:

This is in response to your April 14, 2008 letter regarding the applicability of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) to cyclohexylamine in concentrations of 13-15 percent.

It is the shipper's responsibility to properly class and describe a hazardous material. This Office does not perform that function. The definitions for flammable liquid and corrosive liquid are found in §§ 173.120 and 173.136 respectively. If you determine that your concentration does not meet either hazard class, and presuming the solution does not meet any other hazard class under the HMR, the material would not be regulated. In response to your second question, if the material meets the definitions of a flammable liquid and a corrosive liquid, and is a packing group II, then the entry "Cyclohexylamine, 8, (3), UN2357, PGII" is an appropriate description.

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


Hattie L. Mitchell

Chief, Regulatory Review and Reinvention

Office of Hazardous Materials Standards

173.120 173.136

Regulation Sections

Section Subject
173.120 Class 3-Definitions
173.137 Class 8-Assignment of packing group