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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 #13-0239 ([Pilot Chemical Company] [Mr. David A. Polland])

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

Interpretation Response Details

Response Publish Date:

Company Name: Pilot Chemical Company

Individual Name: Mr. David A. Polland

Location State: OH Country: US

View the Interpretation Document

Response text:

April 2, 2014

Mr. David A. Pollard
Product Safety Specialist
Pilot Chemical Company
2744 E. Kemper Road
Cincinnati, OH 45241

Ref. No. 13-0239

Dear Mr. Pollard:

This responds to your e-mail requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR 171-180) applicable to exceptions from labeling a package with a subsidiary label as prescribed in § 172.402(a)(2).  In your letter, you request regulatory guidance for a substance that meets the defining criteria for a Packing Group II corrosive liquid and has a flash point that ranges from 107 °F - 125 °F (Packing Group III, flammable liquid).  You ask whether you may continue to use the description “UN2920, Corrosive liquid, flammable, n.o.s., 8 (3), PG II” for the substance while taking advantage of the labeling exception provided in § 172.402(a)(2) for transportation by highway or rail.  

The answer is yes.  A subsidiary label is not required for domestic transportation by highway or rail.  However, permissive labeling is allowed, provided the label represents a hazard presented by the material.  A “FLAMMABLE LIQUID” label conforming to
§ 172.419 is required on such a package when it is offered for transportation by air or vessel, and the substance would be appropriately described as “UN2920, Corrosive liquid, flammable, n.o.s. (Technical Name), 8 (3), PG II.”   

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

172.402, 172.419

Regulation Sections

Section Subject
172.402 Additional labeling requirements
172.419 FLAMMABLE LIQUID label