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Interpretation Response #22-0080

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

Interpretation Response Details

Response Publish Date:

Company Name: Arkema – Health Environment and Safety

Individual Name: Steve Schulte

Location State: PA Country: US

View the Interpretation Document

Response text:

October 7, 2022

Steve Schulte
Arkema – Health Environment and Safety
900 First Ave., Building #2
King of Prussia, PA  19406

Reference No. 22-0080

Dear Mr. Schulte:

This letter is in response to your May 16, 2022, letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to subsidiary labeling requirements for organic peroxides. Specifically, you ask whether your understanding is correct that a hazardous material—in your case "UN3103, Organic peroxide type C, liquid, 5.2, (tert-Butyl hydroperoxide, >79-90%)"—requires both a Division 5.2 hazard label and a Class 8 hazard label, when Column 8 (Notes) of the § 173.225 Table 1 to paragraph (c) - Organic Peroxide Table assigns a number "13."

Your understanding is correct. As indicated in § 173.225(c)(8), Column 8 specifies other applicable provisions, as set forth in the notes following the Table 1 to paragraph (c) - Organic Peroxide Table. Specifically, Note 13 states a corrosive subsidiary risk label is required. Therefore, any material listed in the table that is assigned "13" in Column 8 requires a Class 8 (corrosive) subsidiary hazard label, along with the primary hazard label.

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

173.225, 173.225(c)(8)

Regulation Sections

Section Subject
173.225 Packaging requirements and other provisions for organic peroxides