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Interpretation Response #98-0405 ([ASi International] [Mr. Greg Lemley])

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

Interpretation Response Details

Response Publish Date:

Company Name: ASi International

Individual Name: Mr. Greg Lemley

Location State: OH Country: US

View the Interpretation Document

Response text:

FEB 26, 1998


Mr. Greg Lemley
ASi International
4595 Van Epps Road
Cleveland, OH 44131

Dear Mr. Lemley:

This is in response to your letter dated November 14, 1997, requesting clarification on the applicability of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) to your product, "Magnesium Ferro Silicon." Specifically, you are requesting confirmation that your material does not meet the Division 4.3 (Dangerous When Wet Material) hazard class defining criteria in Part 173 of the HMR.

Under § 173.22, it is the shipper's responsibility to properly classify a hazardous material. This office does not normally perform this function. However, based on the test results provided in your letter, your product, "Magnesium Ferro Silicon", meets the Division 4.3 (Dangerous When Wet Material) hazard class guidelines in the UN Manual of Tests and Criteria. Your test results report the maximum evolution rate of 1.6 liters per kilogram of substance per hour which exceeds the UN Manual of Tests and Criteria, Part III, Section 33 maximum evolution rate of 1 liter per kilogram of substance per hour for Division 4.3 material. Therefore, your product, "Magnesium Ferro Silicon" is subject to the HMR.

I hope this answers your inquiry. If you need additional assistance, do not hesitate to contact us.



Delmer F. Billings
Chief, Regulations Development
Office of Hazardous Materials Standards


Regulation Sections

Section Subject
172.101 Purpose and use of hazardous materials table