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.
Sincerely,
Hattie L. Mitchell
Chief, Regulatory Review and Reinvention
Office of Hazardous Materials Standards
173.22