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Interpretation Response #14-0052 ([Medivators] [Mr. Richard M. Ormsbee])

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

Interpretation Response Details

Response Publish Date:

Company Name: Medivators

Individual Name: Mr. Richard M. Ormsbee

Location State: MN Country: US

View the Interpretation Document

Response text:

April 22, 2014

Mr. Richard M. Ormsbee
Corporate Regulatory Affairs Manager
Medivators
14605 28th Avenue North
Minneapolis, MN 55447

Ref. No. 14-0052

Dear Mr. Ormsbee:

This responds to your March 17, 2014 letter requesting clarification of the hazard classification requirements for a corrosive material under the of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  In your letter, you indicate that you have tested the material in accordance with § 173.137(c)(1) and § 173.137(c)(2) and provide the test results. You ask us to confirm that the results show that the involved material is not regulated under the HMR as a corrosive material.   

In your letter you state that a skin corrosion test and a steel and aluminum corrosion test was conducted on your material in accordance with §§ 173.137(c)(1) and 173.137(c)(2).  After observation for 14 days, the skin corrosion test indicated that there was no tissue destruction and the material did not produce evidence of corrosion.  In addition, the steel and aluminum corrosion testing indicated that the product is not considered corrosive to steel or aluminum.    

The definition of a corrosive material is found in § 173.136 of the HMR and procedures for packing group selection are found in § 173.137.  Section 173.22 states that it is the shipper's responsibility to properly classify a hazardous material. This office does not generally perform that function.  However, based on the information you provide, it is the opinion of this office that the material you describe is not regulated in the HMR as a corrosive material.

I hope this information is helpful.  If you have further questions, please contact this office.

Sincerely,

Robert Benedict
Chief, Standards Development Branch
Standards and Rulemaking Division

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