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Interpretation Response #99-0078 ([Willett Labeling Company] [Ms. Alberta Millar])

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

Interpretation Response Details

Response Publish Date:

Company Name: Willett Labeling Company

Individual Name: Ms. Alberta Millar

Location State: TX Country: US

View the Interpretation Document

Response text:

June 7,1999


Ms. Alberta Millar                       Ref. No. 99-0078
Willett Labeling Company
6314-A Airport Freeway
Fort Worth, TX 76117-5332

Dear Ms. Millar:

This is in response to your fax dated March 25, 1999, and subsequent telephone conversation with Eric Nelson of our staff regarding the classification of pressurized canisters of MEK based ink under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask for advice in classifying these canisters.

Under § 173.22 of the HMR, it is the shipper's responsibility to properly classify a hazardous material,. We are sorry that we can not further assist you in the classification of your product as the information provided to^,us in your fax and subsequent telephone conversation is inadequate.  Generally, manufacturers have the knowledge to properly classify the materials and products they produce, although it may be necessary to enlist an outside laboratory to assist in the classification process, as testing may have to be conducted to see how a product compares to the criteria for various hazard classes.

I hope this satisfies your request.



Thomas G. Allan
Acting Director, Office of Hazardous
Materials Standards


Regulation Sections

Section Subject
173.22 Shipper's responsibility