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Interpretation Response #99-0105 ([Chem Lab Products, Inc.] [Mr. Dana Wm. Somesla])

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

Interpretation Response Details

Response Publish Date:

Company Name: Chem Lab Products, Inc.

Individual Name: Mr. Dana Wm. Somesla

Location State: CA Country: US

View the Interpretation Document

Response text:

June 23,1999


Mr. Dana Wm. Somesla              Ref. No. 99-0105
Chem Lab Products, Inc.
5160 East Airport Drive
Ontario, CA 91761-7611

Dear Mr. Somesla:

This is in response to your letter dated April 15, 1999, requesting clarification on the proper classification of your mixture containing 95% trichloroisocyanuric acid and 5% boric acid, which is used as a flame retardant, under the Hazardous Materials Regulations (HMR; Parts 171-180).

Under § 173.22, it is the shipper's responsibility to properly classify and describe a hazardous material.  This Office generally does not perform this function.  However, we provide assistance when we have the information available.  Trichloroisocyanuric acid, dry is listed as a Division 5.1 oxidizing material in the Hazardous Materials Table (HMT)under  the HMR.  You state that your mixture is produced both in powdered and compressed (tableted) form.  Your test data indicates that the mixture does not meet the defining criteria for either a Division 5.1 oxidizing material or a Division 4.1 flammable solid material.  Therefore, if your mixture does not meet any other hazard class defining criteria in Part 173, and is not a hazardous waste, hazardous substance, or marine pollutant, it is not subject to the HMR.

I hope this satisfies your inquiry.



Delmer F. Billing
Chief, Standards Development
Office of Hazardous Materials Standards


Regulation Sections

Section Subject
172.101 Purpose and use of hazardous materials table