Interpretation Response #22-0040
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
October 3, 2022
Rinchem Company, Inc
917 Lone Oak Rd, Ste 100
Eagan, MN 55121
Reference No. 22-0040
Dear Mr. Strelow:
This letter is in response to your May 3, 2022, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to proper shipping names (PSNs). Specifically, you provide the example of "UN1219, Isopropanol or Isopropyl alcohol, 3, PG II" where Column (2) of the § 172.101 Hazardous Materials Table (HMT) lists both "Isopropanol" and "Isopropyl alcohol" in Roman type as PSN alternatives. You ask whether a shipper may use both—at the same time—for the shipping description of a hazardous material required by § 172.202 or whether the intent is to use only one at a time.
The intent of the shipping description requirements is to include the one PSN that most appropriately describes the material. For example, for "UN3164, Articles, pressurized pneumatic or hydraulic containing non-flammable gas, 2.2" the selected PSN must indicate whether the article is pneumatic or hydraulic—it cannot be both.
However, in the instance of "UN1219, Isopropanol or Isopropyl alcohol, 3, PG II," the PSN alternatives are variations of the chemical name that describes the material itself. In such a case, it would be permissible to show the PSN as one of the alternatives with the other as a chemical or technical group name in parentheses either between the proper shipping name and hazard class or following the basic description—see § 172.202(d)—as such a scenario still accurately describes the material. For example:
- UN1219, Isopropanol (Isopropyl alcohol), 3, PG II
- UN1219, Isopropyl alcohol (Isopropanol), 3, PG II
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
172.101, 172.202, 172.202(d)
|§ 172.202||Description of hazardous material on shipping papers|