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Interpretation Response #08-0105 ([Vital Diagnostics] [Ms. Hardy])

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

Interpretation Response Details

Response Publish Date:

Company Name: Vital Diagnostics

Individual Name: Ms. Hardy

Location State: CA Country: US

View the Interpretation Document

Response text:

June 17, 2008

Ms. Sheila Hardy

VP, General Manager

Vital Diagnostics

1075 Lambert Road, Unit D

Brea, CA 92821

Ref. No. 08-0105

Dear Ms. Hardy:

This responds to your letter requesting verification of the classification of one of your products under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask whether a solution containing 99.1% water and 0.9% picric acid would be regulated under the HMR.

Under §173.22 of the HMR, it is a shipper"s responsibility to properly classify a hazardous material for transportation in commerce. This Office does not normally perform that function. Although you did not provide any additional information relevant to your products 518-018 and 55331, it is the opinion of this Office that these solutions do not meet the definition of a hazardous material and, thus, are not subject to the requirements of the HMR.

I trust this satisfies your inquiry. Please contact us if we can be of further assistance.


Hattie L. Mitchell

Chief, Regulatory Review and Reinvention

Office of Hazardous Materials Standards


Regulation Sections

Section Subject
172.101 Purpose and use of hazardous materials table
173.22 Shipper's responsibility