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Interpretation Response #17-0016 ([Energy & Natural Resources Industries and EHS & Sustainability Products] [Mr. Brian Harmon])

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

Interpretation Response Details

Response Publish Date:

Company Name: Energy & Natural Resources Industries and EHS & Sustainability Products

Individual Name: Mr. Brian Harmon

Location State: PA Country: US

View the Interpretation Document

Response text:

June 20, 2017

Brian Harmon
Energy & Natural Resources Industries and
EHS & Sustainability Products
3999 West Chester Pike
Newtown Square, PA 19073

Reference No. 17-0016

Dear Ms. Harmon:

This letter is in response to your February 6, 2017, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the formatting of organic peroxide technical names. Specifically, you ask whether the HMR permit information in brackets displayed on the Organic Peroxide Table in § 173.225 to be included on a shipping paper without the use of brackets or the phrase "as a," further clarifying that your question does not extend to punctuation, such as dashes or parenthesis used in the chemical name. You provide as an example, "Dibenzoyl peroxide [as a paste] = 52" where brackets with additional information are included in the technical name on the Organic Peroxide Table and note the instructions for displaying the technical name on shipping papers in § 172.203(k) use this same material as an example in the following format: "(dibenzoyl peroxide, paste, <52%)."

Because of the unique hazards posed by organic peroxides, the specific technical name listed in the Organic Peroxide Table in § 173.225 must be provided on the shipping paper. Chemical families of organic peroxides do not necessarily display similar characteristics throughout the entire family. In addition, different concentrations of the same organic peroxide exhibit different characteristics. Section 172.203(k) specifies organic peroxides must include the technical name and the actual concentration being shipped or the concentration range for the appropriate generic listing. Omitting brackets and the phrase "as a" does not adversely impact communication of the specific chemical name or concentration. Therefore, both (dibenyzol peroxide [as a paste] = 52) or (dibenzoyl peroxide, paste < 52) would be an acceptable format for the technical name of an organic peroxide.

I hope this information is helpful. Please contact us if we can be of further assistance.



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

173.225, 172.203(k)

Regulation Sections

Section Subject
172.203 Additional description requirements
173.225 Packaging requirements and other provisions for organic peroxides