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Interpretation Response #19-0090

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

Interpretation Response Details

Response Publish Date:

Company Name: UL Materials and Supply Chain

Individual Name: Kevin Skerrett

Location State: NY Country: US

View the Interpretation Document

Response text:

September 16, 2019

Kevin Skerrett, DGSA
Senior Regulatory Specialist
Regulatory Operations
UL Materials and Supply Chain
23 British American Blvd.
Latham, NY  12110

Reference No. 19-0090

Dear Mr. Skerrett:

This letter is in response to your July 3, 2019, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to hazardous materials descriptions and proper shipping names. Specifically, you ask whether the description for "UN1950, Aerosols, corrosive, Packing Group II or III (each not exceeding 1L capacity)" may be modified on a shipping paper to read either "UN1950, Aerosols, corrosive, Packing Group II (each not exceeding 1L capacity)"; or "UN1950, Aerosols, corrosive, Packing Group III (each not exceeding 1L capacity)." You reference § 172.101(c)(2), which states in part, the word "or" in italics indicates that there is a choice of terms in the sequence that may alternatively be used as the proper shipping name or as part of the proper shipping name, as appropriate. 

Your understanding is correct. In accordance with § 172.101(c)(2), you may choose either of those descriptions referenced above for the shipping paper, depending on which one correctly identifies the material based on the packing group of the corrosive hazard. In this instance, there is a choice of terms in the sequence that may be alternatively used as part of the proper shipping name, although not required. 

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

172.101(c)(2)

Regulation Sections

Section Subject
172.101 Purpose and use of hazardous materials table