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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 #19-0104

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 Utilities Commission of Ohio

Individual Name: Tom Forbes

Location State: OH Country: US

View the Interpretation Document

Response text:

April 24, 2020

Tom Forbes
Public Utilities Commission of Ohio
180 E. Broad Street
Suite 431
Columbus, OH 43215

Reference No. 19-0104

Dear Mr. Forbes:

This letter is in response to your August 6, 2019, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the classification of a marine pollutant. Specifically, you ask whether the material described in your email as a brightener solution that contains 35-40%, alcohols, C10-C16 ethoxylate meets the definition of a marine pollutant.

In accordance with the definition of a marine pollutant in § 171.8, a marine pollutant means a material which is listed in Appendix B to § 172.101 of the HMR (also see § 171.4) and, when in a solution or mixture of one or more marine pollutants, is packaged in a concentration which equals or exceeds: (1) Ten percent by weight of the solution or mixture for materials listed in the appendix; or (2) one percent by weight of the solution or mixture for materials that are identified as severe marine pollutants in the appendix.

It is the shipper's responsibility to classify their material. Alcohol C-12-C-16 poly(1-6) ethoxylate is listed as a marine pollutant in Appendix B of § 172.101. This entry includes ethoxylated alcohols from twelve (12) to sixteen (16) the range of polymers from C-12 to C-16. If the shipper determines that the brightener solution contains 10 percent by weight of these molecules, it is considered a marine pollutant.

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


Dirk Der Kinderen
Chief, Standards Development Branch
Standards and Rulemaking Division

171.4, 171.8, 172.101

Regulation Sections

Section Subject
171.4 Marine pollutants
171.8 Definitions and abbreviations
172.101 Purpose and use of hazardous materials table