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Interpretation Response #14-0043 ([Currie Associates, Inc.] [Mr. John V. Currie])

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

Interpretation Response Details

Response Publish Date:

Company Name: Currie Associates, Inc.

Individual Name: Mr. John V. Currie

Location State: NY Country: US

View the Interpretation Document

Response text:

April 22, 2014

Mr. John V. Currie
CEO and Chief Technical Officer
Currie Associates, Inc.
10 Hunter Brook Lane
Queensbury, NY  12804

Ref. No.: 14-0043

Dear Mr. Currie:

This is in response to your March 6, 2014 letter, requesting guidance on how to properly describe a crude sulfate turpentine solution under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you request confirmation that “UN1299, Turpentine solution, Class 3, PG III, RQ (contains Methyl mercaptan)” more appropriately describes the material than “UN1993, Flammable liquid, n.o.s. (contains Turpentine, Dimethyl sulfide), Class 3, PG III, RQ (Methyl mercaptan).

In your letter you provide the material characteristics. The crude sulfate turpentine solution meets the definition of a Class 3 flammable liquid assigned to packing group III.  The solution is comprised of: Turpentine and terpene hydrocarbon isomers (97-99%); Methyl mercaptan (0.2 to 2.5%); Dimethyl sulfide (1 to 2.5%); and Dimethyl disulfide (0 to 1.3%).   The crude sulfate turpentine is a solution that is not identified by name in the § 172.101 Hazardous Materials Table (HMT), but is comprised of a single predominant hazardous material (Turpentine) identified in the HMT by technical name and one or more hazardous and/or non-hazardous materials. In addition, you describe that the HMT entry for Turpentine does not meet the exceptions provided § 172.101(c)(10)(i)(A) through (F), thus requiring the selection of “Turpentine solution” as the proper shipping name.

Your understanding is correct. The most appropriate basic description is “UN1299, Turpentine solution, Class 3, PG III, RQ (contains Methyl mercaptan).” Section 172.101(c)(10) sets forth the criteria for selecting a proper shipping name of a mixture or solution not identified  specifically by name in the HMT. Section 172.101(c)(10)(i) requires that a mixture or solution comprised of a single predominant hazardous material identified by technical name in the HMT and one or more hazardous and/or non-hazardous material must be described with the proper shipping name of the predominant hazardous material and the qualifying word "mixture" or "solution," unless the mixture or solution meets one or more of the conditions in subparagraphs (A) through (F).  

The requirements for generic or “N.O.S.” proper shipping name selection in § 172.101(c)(10)(iii) are intended for mixtures or solutions not comprised of a single predominant hazardous material identified in the HMT.

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

Sincerely,

Duane A. Pfund
International Standards Coordinator
Standards and Rulemaking Division

172.101

Regulation Sections

Section Subject
172.101 Purpose and use of hazardous materials table