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Interpretation Response #09-0076 ([Arkema, Inc.] [Ms. Christina M. Kurtz])

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

Interpretation Response Details

Response Publish Date:

Company Name: Arkema, Inc.

Individual Name: Ms. Christina M. Kurtz

Location State: PA Country: US

View the Interpretation Document

Response text:

November 12, 2009




Ms. Christina M. Kurtz

Arkema, Inc.

2000 Market St., 24th Floor

Philadelphia, PA 19103

Ref. No. 09-0076

Dear Ms. Kurtz:

This is in response to your letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) regarding the appropriate selection of a proper shipping name. Specifically, you ask whether a generic chemical name may be used for the technical name with the concentration added when transporting an organic peroxide in place of the specific name as shown in the § 173.225 Organic Peroxide Table.

The answer is no. A generic chemical name may not be used in place of the technical name listed in the § 173.225 Organic Peroxide Table. Because of the unique hazards posed by organic peroxides, the specific technical name as listed in the Organic Peroxide Table must be used. Chemical families of organic peroxides do not necessarily display similar characteristics throughout the entire family. In addition, different concentrations of the same organic peroxide exhibit different characteristics, so the proper shipping name must include the actual concentration being shipped or the concentration range for the appropriate generic listing. See § 172.101 (c)(6).

I hope this information is helpful. Please contact this office should you have additional questions.


Hattie L. Mitchell

Chief, Regulatory Review and Reinvention

Office of Hazardous Materials Standards

173.225, 172.101(c)(6)

Regulation Sections

Section Subject
172.101 Purpose and use of hazardous materials table
173.225 Packaging requirements and other provisions for organic peroxides