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Interpretation Response #08-0138 ([Polymerics, Inc.] [Mr. William R. Sanderson])

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

Interpretation Response Details

Response Publish Date:

Company Name: Polymerics, Inc.

Individual Name: Mr. William R. Sanderson

Location State: OH Country: US

View the Interpretation Document

Response text:

June 20, 2008

Mr. William R. Sanderson

Environmental Health and Safety Manager

Polymerics, Inc.

2828 Second Street

Cuyahoga Falls, OH 44221

Ref. No.: 08-0138

Dear Mr. Sanderson:

This is in response to your March 26, 2008 letter and subsequent telephone conversation with a member of my staff requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to a rubber compound containing a hazardous substance.

According to your letter, your company produces a rubber compound partially consisting of ethylene thiourea, a hazardous substance with a reportable quantity (RQ) of 10 pounds (4.54 kilograms). The rubber compound is formed into 2-3 pound slabs consisting of approximately 75% ethylene thiourea by weight. You state the polymer matrix greatly lessens or eliminates the hazard posed by the material, similar to asbestos fixed in a natural or artificial binder material.

Appendix A of the Hazardous Materials Table (HMT; § 172.101) lists materials that are designated as hazardous substances and their corresponding RQs. Ethylene thiourea is such a material and, thus, is regulated as a hazardous substance under the HMR. However, provided your material does not meet the RQ for ethylene thiourea in pounds (kilograms) in one package and does not meet any of the criteria of a hazardous material specified in § 171.8, it would not be subject to the HMR.

When bound in a natural or artificial binder, asbestos is excepted from the HMR by § 172.102, Special provision 156. No such exception exists for ethylene thiourea.

I hope this information is helpful. Please contact us if you require additional assistance.


John A. Gale

Chief, Standards Development

Office of Hazardous Materials Standards

172.101 171.8

Regulation Sections

Section Subject
172.101 Purpose and use of hazardous materials table