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Interpretation Response #09-0054 ([Ricca Chemical Company LLC] [Mr. Loren K. Lowry])

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

Interpretation Response Details

Response Publish Date:

Company Name: Ricca Chemical Company LLC

Individual Name: Mr. Loren K. Lowry

Location State: TX Country: US

View the Interpretation Document

Response text:

April 16, 2009




Mr. Loren K. Lowry

Director of Quality Assurance and Regulatory Affairs

Ricca Chemical Company LLC

448 West Fork Drive

Arlington, TX 76012

Ref. No.: 09-0054

Dear Mr. Lowry,

This is in response to your March 12, 2009 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 100-185). Specifically, you request confirmation that a product containing 0.1% Picric Acid (2,4,6-Trinitrophenol) dissolved in acetone may appropriately be described as Acetone, UN1090.

Under § 173.22, it is the shipper"s responsibility to class and describe a hazardous material. This Office does not normally perform this function. Picric acid (UN0154) is explosive when dry and requires approval from the Associate Administration prior to transport of the material. However, it is the opinion of this Office that a 0.1% concentration of picric acid is sufficiently diluted in solution so that the solution is not regulated as a Class 1 explosive or as a Class 3 desensitized explosive liquid. Therefore, "UN1090, Acetone, 3, II" is appropriate to describe the product.

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


Hattie L. Mitchell

Chief, Regulatory Review and Reinvention

Office of Hazardous Materials Standards


Regulation Sections

Section Subject
173.22 Shipper's responsibility