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Interpretation Response #09-0233 ([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:

December 15, 2009




Mr. Gene Sanders

Senior Dangerous Goods Transportation Specialist

Thermo Fisher Scientific

2000 Park Lane

Pittsburgh, PA 15275 USA

Ref. No. 09-0233

Dear Mr. Sanders:

This responds to your October 15, 2009 request for clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask for assistance in determining the hazard class for your alcohol mixture.

According to your letter, your product (Fast Orange G ; Pigment Orange 13, Pyrazolone Orange, C.I. 21110, CAS#3520-72-7) has a chemical structure that, according to Appendix 6 to the United Nations Manual of Tests and Criteria, fourth revised edition, may result in unintended explosive or self-reactive properties. You do not have test data that indicates whether this material meets the definition of a Class 1 (explosive) or a Division 4.1 (self-reactive) material. You state that the Fast Orange G is diluted to less than 1% with common alcohols, water, and less than 1% Phosphotungstic acid. You suggest that at this concentration, even if pure Fast Orange G met the definition for a Class 1 (explosive) material, it has been sufficiently desensitized that it no longer exhibits explosive characteristics.

Section 173.22 requires a shipper to properly class and describe a hazardous material for transportation in commerce. This Office does not perform that function. However, based on the information provided in your letter and the MSDS enclosed in your letter, it is the opinion of this Office that your product should be described as "UN1993, Flammable liquid solution, n.o.s., 3, II."

I hope this answers your inquiry. If you need further assistance, please contact this Office.


Charles E. Betts

Chief, Standards Development

Office of Hazardous Materials Standards


Regulation Sections

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