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Interpretation Response #09-0042 ([Thermo Fisher Scientific, Customer Channels Group] [Mr. Gene Sanders])

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

Interpretation Response Details

Response Publish Date:

Company Name: Thermo Fisher Scientific, Customer Channels Group

Individual Name: Mr. Gene Sanders

Location State: PA Country: US

View the Interpretation Document

Response text:

March 18, 2009

Mr. Gene Sanders

Senior Dangerous Goods Transportation Specialist

Thermo Fisher Scientific, Customer Channels Group

2000 Park Lane

Pittsburgh, PA 15275

Ref. No. 09-0042

Dear Mr. Sanders:

This responds to your February 20, 2009 letter requesting a review of three products and their classification under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). In your letter you enclosed three Material Safety Data Sheets (MSDS), one for each product in question. Specifically, you would like a letter confirming your conclusions regarding the classification of these products as hazardous materials and their respective proper shipping names, and their eligibility for the small quantities exceptions provided in § 173.4. You state two products would be described as "UN1993, Flammable liquids, n.o.s. (Methanol, Acetonitrile), 3, PG II" and the third as "UN1648, Acetonitrile solution, 3, PG II."

In accordance with § 173.22, it is the shipper's responsibility to properly class and describe a hazardous material. This Office does not perform that function. However, based on the information you provided in your letter and enclosed MSDS"s, it is the opinion of this Office that the proper shipping names and identification numbers you selected are appropriate, provided the products do not meet the definitions of any other hazard classes, such as Division 6.1. Also, the products are eligible for the exceptions authorized in § 173.4, provided all applicable requirements are met.

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

173.22, 173.4

Regulation Sections

Section Subject
173.22 Shipper's responsibility
173.4 Small quantities for highway and rail