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Interpretation Response #13-0227 ([Shane Havoc Consulting, LLC] [Mr. Gregory Sutherland])

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

Interpretation Response Details

Response Publish Date:

Company Name: Shane Havoc Consulting, LLC

Individual Name: Mr. Gregory Sutherland

Location State: SC Country: US

View the Interpretation Document

Response text:

July 30, 2014.

Gregory Sutherland Ph.D. (DGSA)
Shane Havoc Consulting, LLC
1905 English Ivy Ct.
Mount Pleasant, SC 29464

Ref. No. 13-0227

Dear Mr. Sutherland:

This is in response to your November 22, 2013 e-mail requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR 171-180) applicable to the classification of Class 8 (corrosive material). Specifically, you request guidance on authorized methods for determining the corrosivity of a solid substance.

For purposes of the HMR, a Class 8 (corrosive material) means a liquid or solid that causes full thickness destruction of human skin at the site of contact within a specified period of time (see §173.136). A liquid, or a solid which may become liquid during transportation, that has a severe corrosion rate on steel or aluminum based on the criteria in §173.137(c)(2) is also a corrosive material. Whenever practical, in vitro test methods authorized in §173.137 of the HMR should be used to determine whether a material is corrosive.

The corrosivity of a solid substance must be determined using data obtained from tests conducted in accordance with the Organization for Economic Cooperation and Development (OECD) Guideline for the Testing of Chemicals, Number 430, "In Vitro Skin Corrosion: Transcutaneous Electrical Resistance Test (TER)" or Number 431, "In Vitro Skin Corrosion: Human Skin Model Test" or Number 404, "Acute Dermal Irritation/Corrosion." For a solid substance, testing protocol varies depending on the method used but, generally, requires that a solid substance be slightly wetted once in place for testing. The OECD Guidelines can be downloaded at the following link:

I trust this information is helpful. Please contact us if you require further assistance.


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

173.136, 173.137, 173.137(c)(2)

Regulation Sections

Section Subject
173.136 Class 8-Definitions
173.137 Class 8-Assignment of packing group