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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 #23-0069

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

Interpretation Response Details

Response Publish Date:

Company Name:

Individual Name: Elizabeth M. Richardson

Location State: DC Country: US

View the Interpretation Document

Response text:

November 6, 2023

Elizabeth M. Richardson
1900 N Street NW 
Suite 100
Washington, DC  20036

Reference No. 23-0069

Dear Ms. Richardson:

This letter is in response to your July 24, 2023, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to organic peroxides. Specifically, you ask for clarification on the bulk packaging requirements for "UN3109, Organic peroxide, type F, liquid, 5.2, 8, (Peracetic acid ≤ 23% hydrogen peroxide)." Although this hazardous material is not listed in the § 173.225(g) Organic Peroxide Portable Tank Table, you seek confirmation of your understanding that it may be transported in cargo tank motor vehicles because the § 173.225(h)(2) provisions do not specify any particular organic peroxide  authorized for transport.

Your understanding is not correct. Section 173.225(h) states that "bulk packagings are authorized—subject to the conditions and limitations of this section—if the organic peroxide is listed in the Organic Peroxide Portable Tank Table and bulk packagings are authorized, or if the organic peroxide is specifically authorized for transport in a bulk packaging by this paragraph (h)." UN3109, Peracetic acid ≤ 23% hydrogen peroxide is neither listed in the Organic Peroxides Portable Tank Table nor is it specifically authorized in bulk packages by § 173.225(h); therefore, it may not be transported in cargo tank motor vehicles without prior approval by the Associate Administrator.

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(g), 173.225(h), 173.225(h)(2)

Regulation Sections

Section Subject
173.225 Packaging requirements and other provisions for organic peroxides