USA Banner

Official US Government Icon

Official websites use .gov
A .gov website belongs to an official government organization in the United States.

Secure Site Icon

Secure .gov websites use HTTPS
A lock ( ) or https:// means you’ve safely connected to the .gov website. Share sensitive information only on official, secure websites.

U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #08-0108 ([Brenntag Mid-South, Inc.] [Mr. A.B. Eargood])

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

Interpretation Response Details

Response Publish Date:

Company Name: Brenntag Mid-South, Inc.

Individual Name: Mr. A.B. Eargood

Location State: KY Country: US

View the Interpretation Document

Response text:

May 13, 2008



Mr. A.B. Eargood

Brenntag Mid-South, Inc.

P.O. Box 20

Henderson, KY 42420

Reference No. 08-0108

Dear Mr. Eargood:

This is response to your April 11, 2008 letter concerning the Hazardous Materials Table (§ 172.101) entry for "UN 1791, Hypochlorite solutions, 8 (corrosive), PG II" in the

October 1, 2007 edition of the Hazardous Materials Regulations (HMR; 49 CFR Parts

171-180). You asked if the "PG III" designation present in earlier editions of the HMR had been inadvertently deleted.

The answer is yes. The PG III entry for the proper shipping name hypochlorite solutions was inadvertently removed when this entry was revised in a December 29, 2006 final rulemaking published under Docket No. PHMSA-06-25476 (HM-215I; 71 FR 78596, 78622). This error will be corrected in a future rulemaking. In the interim, the PG III entry may continue to be used for hypochlorite solutions that meet the defining criteria for a PG III Class 8 liquid prescribed in § 173.137.

Thank you for bringing this matter to our attention. I hope this information is helpful.


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
173.137 Class 8-Assignment of packing group