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Interpretation Response #99-0219 ([Uniroyal Chemical Company, Inc.] [Mr. Donald Hodder])

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

Interpretation Response Details

Response Publish Date:

Company Name: Uniroyal Chemical Company, Inc.

Individual Name: Mr. Donald Hodder

Location State: CT Country: US

View the Interpretation Document

Response text:

September 8, 1999


Mr. Donald Hodder                          Ref.  No. 99-0219
Global HA.ZMAT Compliance Manager
Uniroyal Chemical Company, Inc.
Middlebury, CT 06749

Dear Mr. Hodder:

This is in response to your letter dated July 30, 1999, regarding the selection of a proper shipping name under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  In your letter, you request clarification on the proper shipping name for a mixture containing various ranges of acetic acid.  You stated the material is currently described as “Dyes, liquid, corrosive, n.o.s. (Acetic Acid);” however, you would like to use the proper shipping name “Acetic acid solution.”

Under § 173.22, it is the shipper's responsibility to properly class and describe the material.  However, based on the information you provided, it is our determination that either proper shipping name would be correct for the mixture.

I hope this satisfies your request.


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

172.101, 173.22

Regulation Sections

Section Subject
172.101 Purpose and use of hazardous materials table
173.22 Shipper's responsibility