Interpretation Response #17-0067
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Public Works - Naval Station Everett
Individual Name: Andrew Roley
Location State: WA Country: US
View the Interpretation Document
Response text:
November 16, 2017
Andrew Roley
Public Works
Naval Station Everett
2000 W Marine View Drive
Everett, WA 98207
Reference No. 17-0067
Dear Mr. Roley:
This letter is in response to your June 14, 2017, e-mail requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to classification. Specifically, you ask whether the products listed in the Material Safety Data Sheets (MSDS) you provided would be considered hazardous materials under the HMR.
In accordance with § 173.22 of the HMR, it is the shipper's responsibility to classify a hazardous material. This Office does not normally perform this function. However, based on the information provided in your e-mail, it is the opinion of this Office that both the "All Purpose SAE 10W-40 Four Stroke Engine Oil" and "TGMO SN 5W-30" oil have flash points above 200°F and are not considered to be a flammable or combustible liquid under the HMR. Therefore, provided these oils do not meet any other hazard classes, they would not be subject to the requirements of the HMR.
I hope this information is helpful. Please contact us if we can be of further assistance.
Sincerely,
T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division
173.22
Regulation Sections
| Section | Subject |
|---|---|
| 173.22 | Shipper's responsibility |