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Interpretation Response #98-0509 ([Wood Kote Products, Inc] [Mr. Gary P. Velikanje])

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

Interpretation Response Details

Response Publish Date:

Company Name: Wood Kote Products, Inc

Individual Name: Mr. Gary P. Velikanje

Location State: OR Country: US

View the Interpretation Document

Response text:

APR 17, 1998


Mr. Gary P. Velikanje
Wood Kote Products, Inc
8000 N.B. 14th Place
Portland, OR 97211

Dear Mr. Velikanje:

This is in response to your letter of October 16, 1997, regarding the packaging of a two component wood bleach kit consisting of an aqueous solution of hydrogen peroxide (28%) and an aqueous solution of sodium hydroxide with a buffer of silicic acid. You request clarification under the provisions of the Hazardous Materials Regulations (HMR; 49 CFRParts 171-180).

Specifically, you asked if a two part kit consisting of one inner container of a material described as Hydrogen peroxide, aqueous solution, 5.1, UN 2014 with a Class 8 subsidiary hazard, and one inner container of a material describe as Sodium hydroxide solution, 8, UN 1824, PG IT may be placed in the same outside packaging for transport by vessel. You expressed concern that ocean carriers will not accept these shipments although they have been prepared in accordance with the HMR and the International Maritime Dangerous Goods (]MGD) Code.

Yes, these materials may be packaged together in the same outside package provided they are in accordance with 49 CFR 173.21 (e). As indicated in paragraph 3.6 in Annex I of the General Introduction to the IMDG Code, Amendment 28 (see IMDG Code page 0509), a corresponding provision specifies that materials may not be packaged together in the same outer packaging with other material if they react dangerously to each other and cause combustion and/or evolution of considerable heat, evolution of flammable, poisonous or asphyxiate gases, or the formation of corrosive or unstable substances.

In addition, it is the shippers responsibility to ensure that your materials are properly packaged, marked and labeled. Each material within the package, must be described on the shipping paper and marked on the outside package. The package must be labeled with a Division 5.1 label and a Class 8 label for the primary hazard of the materials.

I hope that this information is helpful. !f you need further assistance, please contact us.



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

Regulation Sections

Section Subject
173.21 Forbidden materials and packages