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Interpretation Response #98-0240 ([Musashino Chemical Laboratory,] [Mr. Yukawa Muneaki])

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

Interpretation Response Details

Response Publish Date:

Company Name: Musashino Chemical Laboratory,

Individual Name: Mr. Yukawa Muneaki

Country: JP

View the Interpretation Document

Response text:

OCT 23, 1998


Mr. Yukawa Muneaki                          Ref. No. 98-0240
Technical Department Manager
Musashino Chemical Laboratory,
Yaesu-Daibiru Bldg.
1-1, Kyobashi I-Chorne, Chuo-
Ku Tokyo 104 Japan 0031

Dear Mr. Muneaki:

This is in response to your letter dated August 18, 1998, regarding the applicability of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) to lactic acid and its derivatives. Specifically, you ask if lactic acid is a class 8 material as defined in the HMR. You also state that it is your understanding that lactic acid is a class 8 material based on the dermal irritation/corrosion classification contained in the 1992 Organization for Economic Cooperation and Development (OECD) Guideline for Testing of Chemicals.

Under § 173.136 of the HMR, class 8 materials are liquids or solids that cause full and irreversible thickness destruction of human skin at the site of contact within a specified period of time. A liquid that has a severe corrosion rate on steel or aluminum based on the criteria in § 173.137(c) (2) is also a corrosive material. A packing group is assigned to the material after evaluating data obtained from testing conducted in accordance with OECD Guidelines, and then determined from the criteria specified in § 173.137.

If your material has been tested for skin corrosion using a previously authorized test method and found to be not corrosive, there is no need to retest it. If you choose to have your material retested, however, and it meets, for example, class 8, packing group III, a proper shipping name then must be selected from the generic or n.o.s. descriptions corresponding to the specific hazard class and packing group for the material and it must be offered for transportation in accordance with the applicable requirements.

I hope this satisfies your inquiry. Also, I have enclosed some informational material. Please contact us if we can be of further assistance.



Hattie L. Mitchell, Chief
Regulatory Review and Reinvention
Office of Hazardous Materials Standards


Regulation Sections

Section Subject
172.101 Purpose and use of hazardous materials table