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Interpretation Response #98-0133 ([Sumitomo Corporation of America] [Mr. Thomas M. Riederer])

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

Interpretation Response Details

Response Publish Date:

Company Name: Sumitomo Corporation of America

Individual Name: Mr. Thomas M. Riederer

Location State: PA Country: US

View the Interpretation Document

Response text:

JUN 23, 1998

 

Mr. Thomas M. Riederer                     Ref. No.: 98-0133
Sumitomo Corporation of America
5000 USX Tower
600 Grant Street
Pittsburgh, PA 15219

Dear Mr. Riederer:

This is in response to your letter of June 15, 1998, regarding the classification of your product, containing 75% ferrosilicon under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  You state that you have had your product tested in accordance with the test method described in Appendix E to Part 173, and found it does not meet the definition of a Dangerous When Wet material.

As provided in § 173.22, it is the shipper’s responsibility to properly classify a hazardous material; however, based on the test data you provided, we agree that your product with 75% ferrosilicon does not meet the definition of a Division 4.3 (Dangerous When Wet) material.  Therefore, if your company’s product does not meet any other hazard class definition in Part 173, it is not subject to the HMR.

I hope this satisfies your request.

Sincerely,

 

John A. Gale
Transportation Regulations Specialist
Office of Hazardous Materials Standards

173.124

Regulation Sections

Section Subject
173.124 Class 4, Divisions 4.1, 4.2 and 4.3-Definitions