Interpretation Response #12-0104 ([Hach Company] [Ms. Dragana Kostic Veneziano])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Hach Company
Individual Name: Ms. Dragana Kostic Veneziano
Location State: IA Country: US
View the Interpretation Document
Response text:
June 13, 2012
Ms. Dragana Kostic Veneziano
Hach Company
100 Dayton Ave
Ames, Iowa 50010
Reference No.: 12-0104
Dear Ms. Kostic Veneziano:
This responds to your email dated April 27, 2011 requesting the proper hazard classification and description of a solution of granulated calcium hydride suspended in Isooctane under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask for guidance in selecting a proper shipping description and whether you are permitted to designate this solution with two separate proper shipping descriptions ("UN 1404, Calcium hydride, 4.3 Packing Group I" and "UN 1262, Octanes, 3, Packing Group II").
According to your email and the supporting test data you provided, the solution of granulated calcium hydride suspended in Isooctane was tested using a Department of Transportation (DOT) approved method and was found to meet the classification criteria for Division 4.3 and Class 3.
As specified in § 173.22 of the HMR, it is the shipper's responsibility to properly classify a hazardous material. This Office does not generally perform that function. However, based on your email and supporting test data, it is the opinion of this Office that designating a solution of granulated calcium hydride suspended in Isooctane with two separate proper shipping descriptions ("UN 1404, Calcium hydride, 4.3 Packing Group I" and "UN 1262, Isooctane, 3, Packing Group II") is incorrect. Based on your data, it is also the opinion of this Office that "UN 3482, Alkaline earth metal dispersions, flammable, 4.3, (3), Packing Group I" is the most appropriate proper shipping description as Calcium hydride may be considered the hydride of an alkaline earth metal and Isooctane is a flammable liquid.
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 |