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Interpretation Response #09-0056 ([Mr. Gene Sanders] [Thermo Fisher Scientific])

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

Interpretation Response Details

Response Publish Date:

Company Name: Mr. Gene Sanders

Individual Name: Thermo Fisher Scientific

Location State: PA Country: US

View the Interpretation Document

Response text:

April 2, 2009




Mr. Gene Sanders, DGSA

Senior Dangerous Good Transportation Specialist

Thermo Fisher Scientific

2000 Park Lane

Pittsburgh, PA 15275

Ref. No. 09-0056

Dear Mr. Sanders:

This responds to your March 13, 2009 email requesting clarification of the classification and description of a product under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you request confirmation that you appropriately class and describe a solution of 99.9% acetone and 0.1% picric acid (trinitrophenol) as "UN1090, Acetone solution, 3, II" and whether the product is eligible for limited quantity exceptions.

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 and the product would be eligible for limited quantity exceptions under § 173.150. We note that the qualifying word "solution" must not be added to the proper shipping name. For purposes of the HMR, use of the qualifying word applies to a solution comprised of a hazardous material identified in the § 172.101 Hazardous Materials Table (HMT) and a non-hazardous material.

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


Charles E. Betts

Chief, Standards Development

Office of Hazardous Materials Standards

173.150, 172.101


Regulation Sections

Section Subject
172.101 Purpose and use of hazardous materials table
173.150 Exceptions for Class 3 (flammable and combustible liquids)
173.22 Shipper's responsibility