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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 #18-0022

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

Interpretation Response Details

Response Publish Date:

Company Name: Ercros

Individual Name: David Nicolau Tous

Location State: B Country: ES

View the Interpretation Document

Response text:

November 15, 2018

David Nicolau Tous
International Sales Manager
Ercros
Avda. Diagonal 595 4a
Barcelona 08014
Spain

Reference No. 18-0022

Dear Mr. Nicolau Tous:

This letter is in response to your February 21, 2018, email and subsequent phone conversations requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to classification.  Specifically, you ask if your paraformaldehyde mixture would be considered a Class 4.1 flammable solid material for transport under the HMR.

Section 173.22 states that it is the shipper's responsibility to class and describe a hazardous material in accordance with Parts 172 and 173 of the HMR. This Office does not normally perform that function. In your initial letter, you provided us with several tests for different concentrations of your material. The tests were done in accordance with the Transport of Dangerous Goods, Manual of Tests and Criteria - Section 33 paragraph 33.2.1.4 and showed that the mixtures did not meet the definition of a Class 4.1 flammable solid. However, if the material or any component of the material meets the definition and criteria of another hazard class, it is the shipper's responsibility to class and describe the hazardous materials.

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
Standards and Rulemaking Division

Regulation Sections

Section Subject
173.22 Shipper's responsibility