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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #99-0160 ([Applied Specialties Inc.] [Ms. Adrienne B. Scheurman])

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

Interpretation Response Details

Response Publish Date:

Company Name: Applied Specialties Inc.

Individual Name: Ms. Adrienne B. Scheurman

Location State: OH Country: US

View the Interpretation Document

Response text:

August 4, 1999


Ms. Adrienne B. Scheurman                Ref. No. 99-0160
Applied Specialties Inc.
33555 Pin Oak Parkway
Avon Lake, OH 44012

Dear Ms. Scheurman:

This is in response to your letter dated June 7, 1999, regarding the proper classification of your ammonium hydroxide solution under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-
180). Specifically, as stated in your letter, your material meets the definition of a corrosive material in Packing Group II under 173.136 and 173.137.                   

Under 173.22, it is the shipper's responsibility to properly classify a hazardous material.  Such determinations are not required by this office. However, based on your analysis that the material 
would meet the definition of a corrosive material in Packing Group II, you are correct in your determination that "Ammonia solutions, 8, UN 2672, PG III" is not an appropriate proper shipping name.  Section 172.101(c)(12)(I) states that a material shall be described by an appropriate proper shipping name listed in 'association with the correct hazard class, packing group, hazard zone, or subsidiary hazard for the material.  If your material meets the defining criteria of a packing group II, corrosive material, you must describe your material using a proper shipping name that is associated with the correct hazard class and packaging group such as 'Corrosive liquid, basic, inorganic n.o.s."

I hope this satisfies your request.



John A. Gale
Transportation Regulations Specialist
Office of Hazardous Materials Standards


Regulation Sections

Section Subject
173.22 Shipper's responsibility