Interpretation Response #09-0069 ([Thermo Fisher Scientific] [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
Individual Name: Mr. Gene Sanders
Location State: PA Country: US
View the Interpretation Document
Response text:
April 15, 2009
Mr. Gene Sanders, DGSA
Senior Dangerous Good Transportation Specialist
Thermo Fisher Scientific
2000 Park Lane
Pittsburgh, PA 15275
Ref. No. 09-0069
Dear Mr. Sanders:
This responds to your February 19, 2009 email requesting clarification of the classification and description of your 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 >99.0 % methanol and less than <1.0% 2,4-Dinitrophenol as "UN1230, Methanol solution, 3, II" and whether the product is eligible for small quantities exceptions.
Under § 173.22, it is the shipper"s responsibility to class a hazardous material. This Office does not normally perform this function. 2,4-Dinitrophenol 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 your solution of <1.0% Dinitrophenol (UN0076) is sufficiently diluted so that it is not regulated as a Class 1 explosive or as a Class 3 desensitized explosive nor is it regulated as a Division 6.1 poisonous material. Therefore, "UN1230, Methanol, 3, II" is appropriate to describe your product and the product would be eligible for small quantity exceptions under § 173.4. 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.
Sincerely,
Charles E. Betts
Chief, Standards Development
Office of Hazardous Materials Standards
173.22