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Interpretation Response #24-0091

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

Interpretation Response Details

Response Publish Date:

Company Name: AdvanSix Inc.

Individual Name: Larry D. Buffey

Location State: NJ Country: US

View the Interpretation Document

Response text:

January 10, 2025

Larry D. Buffey
Dangerous Goods Compliance Leader
AdvanSix Inc.
Attn: Wenfang Chen
300 Kimball Drive Suite 100
Parsippany, NJ  07054

Reference No. 24-0091

Dear Mr. Buffey:

This letter is in response to your September 19, 2024, email and subsequent conversations requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to combustible liquid provisions. Specifically, you ask whether non-bulk, bulk, and reportable quantities of "UN1915, Cyclohexanone, 3, PG III" that meet the reclassification requirements for a combustible liquid would qualify for certain combustible liquid exceptions under § 173.150(f).

If "UN1915, Cyclohexanone, 3, PG III" is properly reclassified as a combustible liquid, shipped in non-bulk packaging, and does not meet the definition of a hazardous substance, hazardous waste, or marine pollutant, the exceptions in § 173.150(f)(2) apply when transported by highway or rail—i.e., the requirements in the HMR do not apply. However, if "UN1915, Cyclohexanone, 3, PG III" is properly reclassified as a combustible liquid and is shipped in bulk packaging or meets the definition of a hazardous substance, hazardous waste, or marine pollutant, the provisions in § 173.150(f)(3) apply when shipped by highway or rail—which provide limited exceptions while maintaining certain requirements including, but not limited to, shipping papers, marking of packages, and placarding when applicable.

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

Sincerely,

Steven Andrews
Acting Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division

173.150(f), 173.150(f)(2), 173.150(f)(3)

Regulation Sections