Interpretation Response #11-0105 ([DuPont Sourcing & Logistics] [Mr. Thomas Reese])

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

Interpretation Response Details

Response Publish Date: 06/09/2011

Company Name: DuPont Sourcing & Logistics

Individual Name: Mr. Thomas Reese

Location State: DE Country: US

View the Interpretation Document

Response text:

June 9, 2011

Mr. Thomas Reese

Distribution Safety & Regulatory Compliance Consultant

DuPont Sourcing & Logistics

4417 Lancaster Pike

Barley Mill Plaza 22/2226

Wilmington, DE 19805

Ref. No.: 11-0105

Dear Mr. Reese:

This responds to your April 18, 2011 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the definition of corrosive materials.

In your letter, you state that your company, Dupont, receives metal corrosion test results for one of its products. You indicate that the laboratory test report for the product states it is not corrosive to metals at a rate of 6.25 mm/yr, but it exhibits "localized corrosion" at the liquid/vapor interface exceeding 120 mm when exposed for seven days. You provide data in an attachment of the metal corrosion test results. You ask if a shipper is required to use both "uniform corrosion" and "localized corrosion" data when determining whether a material meets the definition of a Class 8 corrosive material based on its corrosive effects on aluminum or steel.

The answer is yes. Under the HMR, both tests must be considered when determining if a material is corrosive. It is the opinion of this Office that based on the information from the results of the tests your company performed, your material is considered a Class 8 corrosive material. (See § 173.136.)

I trust this satisfies your inquiry. Please contact us if we can be of further assistance.

Sincerely,

T. Glenn Foster

Chief, Regulatory Review and Reinvention Branch

Standards and Rulemaking Division

173.136

Regulation Sections