Interpretation Response #98-0526 ([Saturn Corporation] [Mr. Daniel T. McDonald])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Saturn Corporation
Individual Name: Mr. Daniel T. McDonald
Location State: TN Country: US
View the Interpretation Document
Response text:
APR 23, 1998
Mr. Daniel T. McDonald
Director of Material Flow and Logistics
Saturn Corporation
100 Saturn Parkway
P.O. Box 1500
Spring Hill, TN 37174-1500
Dear Mr. McDonald:
This in response to your letter dated November 10, 1997, requesting clarification on the applicability of the Hazardous Materials Regulations (HMR; 49 CFRParts 171-180) to your product, "Aluminum Dross". Specifically, you are requesting confirmation that your material does not meet the Division 4.3 (Dangerous When Wet) hazard class defining criteria in Part 173 of theIDAR.
With the exception of explosives, it is the shipper's responsibility to properly classify a hazardous material. See § 173.22. This office does not normally perform this function. However, based on the test results provided in your letter, it would appear that your aluminum dross, would not meet the definition of a Division 4.3 (Dangerous When Wet) material based on your test data, which appears to conform to the procedure specified in Appendix E of 49 CFR Part 173, 1996 edition. Therefore, if your company's product is llilt hot nor wet and does not meet any other hazard class definition in Part 173, it is not subject to the HMR .
I hope this information is helpful. Should you have further questions, do not hesitate to contact us.
Sincerely,
Hattie L. Mitchell
Chief Regulatory Review and Reinvention
Office of Hazardous Materials Standards