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Interpretation Response #98-0412 ([Technical Chemical Company] [Mr. Ruben E. Morales])

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

Interpretation Response Details

Response Publish Date:

Company Name: Technical Chemical Company

Individual Name: Mr. Ruben E. Morales

Location State: TX Country: US

View the Interpretation Document

Response text:

FEB 19, 1998

 

Mr. Ruben E. Morales

Technical Chemical Company

Post Office Box 540095

Dallas, TX 75354

Dear Mr. Morales:

This is in response to your letter regarding dual marking on packages containing "Engine starting fluid," under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) and the International Maritime Dangerous Code (IMDG Code). I apologize for the delay in responding and hope it has not caused any inconvenience.

A fmal rule under Docket H1vf-215B [62 FR 24690; 05106/97] revised the § 172.101 Hazardous Materials Table (§ 172.101 HMT). In this final rule, the description "Engine starting fluid with flammable gas, 2.1, UN 196011 was removed from the § 172.101 HMT, and thus is not an acceptable proper shipping name under the HMR. This final rule is effective 10/1/98 for domestic shipment.

Under the HMR, with certain exceptions, if all or part of the transportation is by vessel, a hazardous material which is classed, packaged, marked, labeled, placarded and described in accordance with the requirements of the IMDG Code may be offered and accepted, and transported in the United States (see § 171. 12(b)).

For your information, in the § 172.101 HMT and the 10th revised edition of the U.N. Recommendations, the designation "Aerosols, 2.1 UN 195011 is the proper shipping name for "Engine starting fluid with flammable gas."

I hope this in formation is helpful. If we can be of further assistance, please contact us.

Sincerely,

 

Delmer F. Billings

Chief, Standards Development

Office of'. Hazardous Materials Standards

172.300

Regulation Sections