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Interpretation Response #11-0303 ([Integrated Chemical & Equipment Corp.] [Mr. Michael Gosselin])

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

Interpretation Response Details

Response Publish Date:

Company Name: Integrated Chemical & Equipment Corp.

Individual Name: Mr. Michael Gosselin

Location State: CT Country: US

View the Interpretation Document

Response text:

June 27, 2012

 

Mr. Michael Gosselin
Integrated Chemical & Equipment Corporation
22 Jefferson Circle
Clinton, CT 06413

Reference No. 11-0303

Dear Mr. Gosselin:

This responds to your letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the classification of hazardous materials. Specifically, you ask how Resin Solution containing Di(4-tert-butylcyclohexyl) Peroxydicarbonate and Tert-Butyl Peroxybenzoate in a felt/glass constructed liner with a thin film coating should be classified. Your understanding is that the compound resin product in a felt/glass constructed liner should be classified as "Resin Solution, UN 1866, Class 3, PG III."

As specified in § 173.22 of the HMR, a shipper is responsible for properly classifying, packaging, marking, and labeling a hazardous material for transportation in commerce. This Office does not typically perform this function. The hazard class of a material is determined based on the chemical composition and hazard properties of the material. If your material meets the definition of any of the hazard classes or is a hazardous substance, a marine pollutant or a hazardous waste, it is regulated under the HMR. Therefore, if the material you have described remains in its liquid form, it should continue to be classified as a "Resin Solution, UN 1866, Class 3, PG III."

I hope 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

173.22

Regulation Sections

Section Subject
173.22 Shipper's responsibility