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Interpretation Response #99-0255 ([Onyx Environmental Services L.L.C.] [Ms. Lauren Malone])

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

Interpretation Response Details

Response Publish Date:

Company Name: Onyx Environmental Services L.L.C.

Individual Name: Ms. Lauren Malone

Location State: NJ Country: US

View the Interpretation Document

Response text:

April 12, 2000

 

Ms. Lauren Malone                           Ref. No. 99-0255
Onyx Environmental Services L.L.C.
Roxbury Business Park
1705 Route 46 West, Unit #2
Ledgewood, NJ 07852

Dear Ms. Malone:

This is in response to your telephone conversation and follow up letter dated September 3, 1999, to Dr. Richard Tarr of the Office of Hazardous Materials Exemptions and Approvals requesting clarification on the hazard class and transportation of forbidden materials that are stabilized or diluted under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).

Your understanding of the provisions addressing forbidden materials per your conversation with Dr. Tarr is correct and is further clarified.  As stated in your letter, if any specifically listed, pure, forbidden material is stabilized or diluted to reduce or eliminate the hazards, it is then no longer considered a forbidden material.  It is your responsibility to ensure it is stabilized, classed and transported in accordance with the HMR.  Organic peroxides, explosives, and self reactive materials always require formal approval from the Associate Administrator for Hazardous Materials Safety.  For other than these materials, no formal approval or authorization is required from DOT to dilute, stabilize, and transport the material.  The proper shipping name "nitrobromobenzene" does not apply to stabilized and diluted "1-bromo-3- nitrobenzene" since it no longer meets the definition for Division 6.1. A solution of 90% ethanol, 10% 1-bromo-3-nitrobenzene presents a flammability hazard, therefore, the proper shipping description "Flammable liquids, n.o.s., (ethanol and nitrobromobenzene), 3, UN 1993, PG 11" is appropriate.

I hope this further clarifies and answers your inquiry.

Sincerely,

 

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

173.21

Regulation Sections

Section Subject
173.21 Forbidden materials and packages