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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 #13-0065 ([Huntsman LLC] [Mr. Mike Stillwell])

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

Interpretation Response Details

Response Publish Date:

Company Name: Huntsman LLC

Individual Name: Mr. Mike Stillwell

Location State: TX Country: US

View the Interpretation Document

Response text:

June 14, 2013


Mr. Mike Stillwell
Team Lead, Transportation Safety and Rail Security Coordinator
Huntsman LLC
8600 Gosling Road
The Woodlands, TX  77831

Ref. No. 13-0065

Dear Mr. Stillwell:

This responds to your March 25, 2013 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to shipping papers.  Specifically, you ask about shipping a Class 8 material containing a marine pollutant under a generic shipping description such as “UN2375, Corrosive Liquid, n.o.s.”  In your letter, you propose two different shipping descriptions and request that the Pipeline and Hazardous Materials Safety Administration (PHMSA) clarify which description is correct based on the wording in § 172.203(k)(1).  The shipping descriptions listed in your letter are as follows:

UN2375, Corrosive liquid, n.o.s. (corrosive component), 8, II marine pollutant (marine pollutant component); or

UN2375, Corrosive liquid, n.o.s. (corrosive component, marine pollutant component), 8, II marine pollutant.

In accordance with § 173.22, it is the shipper's responsibility to properly classify a hazardous material.  This Office does not generally perform that function.  However, based on the information you provided, the appropriate method to describe the material in your scenario would be “UN2375, Corrosive liquid, n.o.s. (corrosive component), 8, II, marine pollutant (marine pollutant component).”  The intention of § 172.203(k)(1) is for only the corrosive component which makes the material a corrosive liquid be included in the shipping description in addition to the generic n.o.s. description.

Thank you for your continued interest in this matter.  If you have any questions regarding the handling of your request, please feel free to contact me directly at (202) 366-8553.


T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division

172.203(k), 173.22

Regulation Sections

Section Subject
172.203 Additional description requirements
173.22 Shipper's responsibility