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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #10-0249 ([Manager Cytec Industries, Inc.] [Mr. Charles Schreier])

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

Interpretation Response Details

Response Publish Date:

Company Name: Manager Cytec Industries, Inc.

Individual Name: Mr. Charles Schreier

Location State: NJ Country: US

View the Interpretation Document

Response text:

January 5, 2011




Mr. Charles Schreier

North American Logistics Manager

Cytec Industries, Inc.

Five Garret Mountain Plaza

Woodland Park, NJ 07424

Ref. No.: 10-0249

Dear Mr. Schreier:

This is in response to your November 10, 2010 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to international shipments of a hazardous material when the international regulations differ from the HMR. You explain that the material is classed as NA1993, Combustible liquid, n.o.s. in the HMR, but is classed as UN3082, Environmentally Hazardous Substance, liquid, n.o.s. in the International Maritime Dangerous Goods (IMDG) Code, and in both regulations the material is considered a marine pollutant. Specifically, you ask if the material must be shipped as NA1993, Combustible liquid, n.o.s., Marine Pollutant, from the U.S. point of origin to the destination overseas.

The HMR allows import and export shipments of hazardous materials to be transported in accordance with the IMDG Code in the United States (§ 171.25). Under § 171.22(c), a material designated as a hazardous material under the HMR, which is not subject to the requirements of the IMDG Code may not be transported under the IMDG Code within the United States.

A material that is a marine pollutant, that does not meet any other hazard class definition, and has a flashpoint between 141° F and 200° F is classed as Class 9 under the IMDG Code and a Combustible liquid under the HMR. Such material is regulated under the IMDG Code and therefore may be transported under the provision of § 171.22(b) as a Class 9 material.

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


Ben Supko

Acting Chief, Standards Development Branch

Standards and Rulemaking Division

171.22, 171.25

Regulation Sections

Section Subject
171.22 Authorization and conditions for the use of international standards and regulations
171.25 Additional requirements for the use of the IMDG Code