Interpretation Response #09-0144
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
July 31, 2009
Mr. Mark Ryan
Cytec Industries
Stamford Hazards Lab
1937 W Main St
Stamford, CT 06902-4516
Ref. No. 09-0144
Dear Mr. Ryan:
This responds to your June 19, 2009 letter requesting clarification on whether the attached ARC test method may be used to determine a material"s self-accelerated decomposition temperature (SADT) under §173.21(f) of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171"180). Specifically, you ask if a test method, other than those listed in Part II, Section 28, test series H of the UN Manual of Tests and Criteria, may be used to meet the requirements of § 173.21(f) of the HMR.
The answer is yes. Section 173.21(f) specifies the SADT may be determined by any of the test methods described in Part II, of the UN Manual of Tests and Criteria. These UN provisions, in 28.2.2, also provide that test methods, other than those listed, are authorized provided the alternative method gives the correct SADT of the material as packaged for transport.
I trust this satisfies your inquiry. Please contact us if we can be of further assistance.
Sincerely,
Hattie L. Mitchell
Chief, Regulatory Review and Reinvention
Office of Hazardous Materials Standards
173.21(f)
Regulation Sections
| Section | Subject |
|---|---|
| § 173.21 | Forbidden materials and packages |