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Interpretation Response #13-0205 ([Reid laboratories LLC] [Mr. Scott Hopkins])

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

Interpretation Response Details

Response Publish Date:

Company Name: Reid laboratories LLC

Individual Name: Mr. Scott Hopkins

Location State: TX Country: US

View the Interpretation Document

Response text:

November 21, 2013

Mr. Scott Hopkins
Director of Marketing
Reid Laboratories LLC
2141Collins Road, Building 901
Denton, TX 76208

Ref. No.: 13-0205

Dear Mr. Hopkins:

This is in response to your email dated October 28, 2013, requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) relating to the hazard classification of a 1.35 percent caustic potash (potassium hydroxide) solution.

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.  Absent the availability of  test data conducted in accordance with § 173.137, or historical test data conducted in accordance with § 173.136(c), the caustic potash solution can only be appropriately classified by conducting the corrosion testing specified in § 173.137.

I trust this information is helpful.  If you have further questions, please do not hesitate to contact this office.


Duane A. Pfund
International Standards Coordinator
Standards and Rulemaking Division

173.22, 173.136, 173.137

Regulation Sections

Section Subject
173.136 Class 8-Definitions
173.137 Class 8-Assignment of packing group
173.22 Shipper's responsibility