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Interpretation Response #11-0021 ([Kajuligan Corporation] [Mr. Clifford Croft])

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

Interpretation Response Details

Response Publish Date:

Company Name: Kajuligan Corporation

Individual Name: Mr. Clifford Croft

Location State: IL Country: US

View the Interpretation Document

Response text:

April 21, 20111



Mr. Clifford Croft

Director of Regulatory Compliance

Kajuligan Corporation

1533 Kirkwood Drive

Geneva, IL 60134

Ref. No. 11-0021

Dear Mr. Croft:

This responds to your January 18, 2011 request for clarification on the hazard class and proper shipping name for 46% Hydrogen Peroxide in a 3 ml syringe under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You state that the manufacturer is listing the classification as "UN 3139, Oxidizing liquid, n.o.s. (Hydrogen peroxide), 5.1, PG II" on the Material Safety Data Sheet (MSDS). You disagree with the manufacturer"s classification of this material. Specifically, you ask for the proper hazard class and proper shipping name for this product.

As provided in § 173.22, it is the shipper"s responsibility to properly classify a hazardous material. Such determinations are not required to be verified by this office. Additionally, you provided no test data or an MSDS to substantiate your disagreement with the manufacturer"s classification of this material. However, the Hazardous Materials Table (HMT) specifically lists "Hydrogen peroxide, aqueous solution, with more than 40% but less than 60% hydrogen peroxide" as a Division 5.1, and requiring both an OXIDIZER and CORROSIVE label. If the hazard class of the material you describe is questionable, the material should be tested for final hazard class determination.

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



Ben Supko

Acting Chief, Standards Development Branch

Standards and Rulemaking Division


Regulation Sections

Section Subject
173.22 Shipper's responsibility