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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 #15-0081 ([LabelMaster Services] [Mr. Robert Richard])

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

Interpretation Response Details

Response Publish Date:

Company Name: LabelMaster Services

Individual Name: Mr. Robert Richard

Location State: IL Country: US

View the Interpretation Document

Response text:

June 10, 2015

Mr. Robert Richard
Vice President Labelmaster Services
5724 N. Pulaski Road
Chicago, IL 60646

Reference No. 15-0081

Dear Mr. Richard:

This is in response to your April 23, 2015 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to test methods for corrosion to metals. In your letter, you state, it is your understanding that a solid material, which is not likely to become liquid during transportation and has a melting point greater than 55°C need not be tested for corrosivity to metals per § 173.137(c)(2). You further state that the solid material is not classified as a Class 8 corrosive substance, unless it causes full thickness destruction of human skin at the site of contact within a specified period of time. You ask whether your understanding is correct.

Provided the material meets the definition of a solid in § 171.8, your understanding is correct. The definition of a corrosive material in § 173.136(a) states, "For the purpose of this subchapter, "corrosive material" (Class 8) means a liquid or solid that causes full thickness destruction of human skin at the site of contact within a specified period of time. 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." While both solids and liquids are subject to the criteria for skin destruction in §173.136(b), only liquids and solids which may become liquid during transportation should be tested in accordance with § 173.137(c)(2).

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


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

173.137(c)(2), 171.8, 173.136(a), 173.136(b)

Regulation Sections

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