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Interpretation Response #09-0049 ([Thermo Fisher Scientific] [Mr. John G. Mayfield])

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

Individual Name: Mr. John G. Mayfield

Location State: PA Country: US

View the Interpretation Document

Response text:

May 11, 2009

 

 

 

 

Mr. John G. Mayfield

Manager, Dangerous Goods Transportation

Customer Channels Group

Thermo Fisher Scientific

2000 Park Lane

Pittsburgh, PA 15275



Ref. No. 09-0049

Dear Mr. Mayfield:

This responds to your March 10, 2009 email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You state that Thermo Fisher has a number of materials which have chemical structures that demonstrate some characteristics of Division 4.1 (Flammable solid) or Class 1 (Explosive) materials. However, you do not have sufficient technical information on the materials to make an appropriate classification. You propose to dilute these materials in a compatible solvent to a concentration of 1% or less. You ask for confirmation that the diluted material would not meet the definition of a Class 1 or a Division 4.1 material for purposes of the HMR.

Under § 173.22, it is the shipper"s responsibility to class and describe a hazardous material. This Office does not normally perform this function. You have not provided the data or information necessary to enable us to confirm that these materials, diluted as described above, would not meet the definition of an explosive or flammable solid material under the HMR.

To facilitate the transportation of your materials, you may wish to request a special permit. Your application should be directed to the Office of Hazardous Materials Special Permits and Approvals and should include specific and detailed information concerning how you propose to package and transport the materials.



The procedures for applying for a special permit are in 49 CFR Part 107, Subpart B. You may also obtain this information at our website at http://www.phmsa.dot.gov/hazmat/regs/sp-a.

I hope this information is helpful. If you have further questions, please do not hesitate to contact this Office.

Sincerely,

Charles E. Betts

Chief, Standards Development

Office of Hazardous Materials Standards

172.101(c)(11), 173.22

Regulation Sections

Section Subject
172.101 Purpose and use of hazardous materials table
173.22 Shipper's responsibility