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Interpretation Response #08-0195 ([LaMotte Co.] [Ms. Irene Penfield])

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

Interpretation Response Details

Response Publish Date:

Company Name: LaMotte Co.

Individual Name: Ms. Irene Penfield

Location State: MD Country: US

View the Interpretation Document

Response text:

September 2, 2008

Ms. Irene Penfield

Regulatory Affairs Coordinator

LaMotte Co.

802 Washington Ave.

PO Box 329

Chestertown, MD 21620

Ref. No.: 08-0195

Dear Ms. Penfield:

This is in response to your July 17, 2008 letter requesting clarification on the proper classification of a wide range indicator under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you request confirmation of your understanding that your wide range indicator meets the definition of a Class 3 (Flammable liquid) material and the small amount of 2,4 Dinitrophenol, wetted does not contribute to the hazard of the solution. According to your letter, the wide range indicator is used to determine the pH of water samples. The wide range indicator is shipped in a 30 ml bottle and is packed with other non-hazardous materials in a kit.

According to the material safety data sheet included with your letter, the wide range indicator is comprised of the following:

" 52 % Ethyl Alcohol

" 2 % Methyl Alcohol

" 0.5 % Sodium hydroxide

" 0.05 % 2,4 Dinitrophenol, wetted

" <0.1 % Phenolpthalein

" <0.5 % various non-hazardous dyes

" Water comprises the remainder of the solution

You state that the wide range indicator is contained in a 30 ml plastic bottle. The bottle has a dropper tip plug, a screw cap over the plug and shrink band tape secures the cap. The bottle is placed into a plastic bag within a kit case. The kit case is placed into a fiberboard box with cushioning material and the fiberboard box is marked in accordance with § 173.4.

It is the opinion of this Office that the wide range indicator described in your letter, meets the definition of a Class 3, flammable liquid, Packing Group II and may utilize the exception provided in § 173.4 applicable to small quantities.

I hope this answers your inquiry.


Susan Gorsky

Acting Chief, Standards Development

Office of Hazardous Materials Standards


Regulation Sections

Section Subject
173.4 Small quantities for highway and rail