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Interpretation Response #09-0119 ([Advance Asymmetrics, Inc.] [Mr. Lawrence D. Rutledge])

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

Interpretation Response Details

Response Publish Date:

Company Name: Advance Asymmetrics, Inc.

Individual Name: Mr. Lawrence D. Rutledge

Location State: IL Country: US

View the Interpretation Document

Response text:

June 19, 2009

 

 

 

Mr. Lawrence D. Rutledge

Advance Asymmetrics, Inc.

213 East White Street

Millstadt, IL 62260-1543



Ref. No. 09-0119

Dear Mr. Rutledge:

This responds to your May 1, 2009 letter requesting an interpretation of your procedure for classifying and describing di-tert-Butyldicarbonate under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).

Under § 173.22, it is the shipper"s responsibility to class and describe a hazardous material. This Office does not perform that function. Your analysis of the physical and chemical properties of di-tert-Butyldicarbonate and your procedure for determining the classification, packing group assignment, and appropriate shipping description provides for a reasonable conservative conclusion. Your understanding is correct that the material is a solid as defined in accordance with § 171.8 and should be described as a solid. However, we are concerned that using a shipping description that identifies the material as a solid when the material may be shipped as a liquid may not convey appropriate information to transport workers and emergency responders. To ensure that complete information concerning the material is provided, you may add the qualifying word "molten" to the shipping description in accordance with § 172.101(c)(16). Alternatively, you may include additional information on the shipping paper to indicate the material may be in a liquid state during the normal course of transportation. Note that when the authorized packaging associated with the shipping description for material is inappropriate for the physical state of the material during transport, § 172.101(i)(4) should be used to determine the appropriate packaging.

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, 172.101, 171.8

Regulation Sections

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