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Interpretation Response #13-0135 ([Patterson Companies, Inc. c/o Patterson Logistics Services, Inc] [Mr. Robb Boros])

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

Interpretation Response Details

Response Publish Date:

Company Name: Patterson Companies, Inc. c/o Patterson Logistics Services, Inc

Individual Name: Mr. Robb Boros

Location State: IA Country: US

View the Interpretation Document

Response text:

July 3, 2013

 

Mr. Robb Boros
Patterson Companies, Inc.
c/o Patterson Logistics Services, Inc.
1905 Lakewood Drive
Boone, IA 50036

Ref No.: 13-0135

Dear Mr. Boros:

This is a response to your June 24, 2013 email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) with regard to the selection of a proper shipping name.  Specifically, you seek clarification on whether you may use the hazardous materials description “UN1266, Perfumery products,” for a product used as a disinfectant or cleaner and not as a perfume.  

In accordance with § 173.22, it is the shipper's responsibility to properly class and describe a hazardous material.  This Office does not perform that function.  There is no definition for “perfumery products” in the HMR.  However, perfume is typically defined as a fluid preparation used for scenting, composed of natural essences or synthetics and a fixative.  Given that the primary function of your product is not as a perfume, but rather, a product intended to be used as a disinfectant or cleaner, the description the description of “UN1266, Perfumery products” would not be appropriate.

I hope this information is helpful.  If you have any more questions, please do not hesitate to contact this office.

Sincerely,

Robert Benedict
Chief, Standards Development
Standards and Rulemaking Division

173.22

Regulation Sections

Section Subject
173.22 Shipper's responsibility