# Fisher Scientific International, Inc. — Hazardous Materials Safety Interpretation

**Citation:** 06-0244  
**Type / status:** guidance / guidance  
**Agency:** Pipeline and Hazardous Materials Safety Administration  
**Effective:** Not stated  
**Published:** 2006-12-07

06-0244 response to Fisher Scientific International, Inc. concerning 172.101.

## Document text

<<<PAGE 1>>>

of Transportation
U.S. Department
Washington, D.C. 20590
400 Seventh Street, S.W.
Pipeline and
Administration
Hazardous Materials Safety
DEL
906
Mr. Gene Sanders
Dangerous Goods
Ref. No.
06-0244
Fisher Scientific
Transportation Specialist
2000 Park Lane
International, Inc.
Pittsburgh, PA
15275
Dear Mr. Sanders:
This
the classification of Hollande's Solution under the
responds to your letter requesting clarification on
180).
Hazardous Materials Regulations (HMR; 49 CFR Parts 171-
properly classified
Specifically, you ask for confirmation that you have
acid, 1.2% methyl alcohol, 1.0-1.5% acetic acid,
a solution consisting of ‹ 2.38% picric
> 90% water.
formaldehyde, 2.0-2.5% copper diacetate monohydrate, and
Based on PH value (3.48) and the minimal
intend to describe it as "UN3265, Corrosive liquid, acidic,
amount of picric acid in Hollande's Solution (< 2.38%) you
organic, n.o.s. (Formaldehyde, Picric acid), 8, III." In
previously issued interpretations that would appear to
addition, you enclosed with your request copies of two
support your decision.
Although the entry in the
§ 172.101 Hazardous Materials
not specify a lower limit for the concentration of picric
Table (HMT) for Picric acid (Trinitrophenol, wetted) does
Hollande's Solution should not be described as a
acid in solution, we agree with your conclusion that
desensitized explosive of Hazard Class 3 or Division 1.1.
172.101
060244

<<<PAGE 2>>>

Therefore, we agree with your decision to describe
Hollande's
organic, n.o.s. (Formaldehyde, Picric acid), 8, III."
Solution as "UN3265, Corrosive liquid, acidic,
we can be of further assistance.
I trust this satisfies your inquiry. Please contact us if
Sincerely,
Hattie L. Mitchell
Office of Hazardous Materials Standards
Chief, Regulatory Review and Reinvention

<<<PAGE 3>>>

stevens
Page 1 or z
3/72.101
Classification Shipping Name
Drakeford, Carolyn <PHMSA>
06 - 0244
From:
Gorsky, Susan <PHMSA>
Sent:
Thursday, October 26, 2006 3:57 PM
To:
Drakeford, Carolyn <PHMSA>
Subject:
FW: Formal Interpretation requested
Attachments: InterpLetter 2000 low percent picric.pdf; InterpLetter 2004 Bouins.pdf; Hollande's solution
MSDS.pdf
For the interp data base. Thanks.
Sent: Thursday, October 26, 2006 3:12 PM
From: Sanders, Gene [mailto: gene.sanders@fishersci.com]
Cc: Mayfield, John; Ke, Charles <PHMSA>; Ke, Charles <PHMSA>
To: Gorsky, Susan <PHMSA>
Subject: Formal Interpretation requested
Ms. Gorsky,
known as Hollande's Solution, MSDS attached.
Fisher Scientific is requesting a formal interpretation regarding the transport classification of a product
material for transport. However, the 49CFR 172.101 Hazardous Materials Table also lists 90%, Trinitrophenol with
Hollande's Solution contains Trinitrophenol (Picric Acid), which when pure (dry) is regulaled as a Class 1
10% water as being adequately desensitized, UN3364. 90% wetted with 10% is a 0.11-fold dilution. In
words, Hollande's Solution is 340 times more dilute than the minimum allowed
Hollande's Solution there is 2.38% Trinitrophenol and at least 90% water, which is a 37.81-fold dilution. In other
MSDS, are expected to sensitize Trinitrophenol, nor to adversely affect the desensitization of Trinitrophenol by
None of the other ingredients in Hollande's Solution, all at concentrations less than 3.2%, and listed in the
So, we believe that this product is more than adequately desensitized.
remains desensitized when precipitated but still wetted.
material, and while Nitroglycerin can be explosive when precipitated from an alcohol solution, Trinitrophenol
workers that it includes a desensitized explosive.
So, we believe that this product does not present a high enough risk to warrant informing transportation
product is corrosive. There are three components of Hollande's Solution that when present in higher
Although the pH of Hollande's Solution is 3.48, it is not always acidity alone that determines whether a
concentrations can each be corrosive on their own. Although none of these three components are believed to
the three, we do reasonably suspect that together they make the product a Class 8 material at the Packing Group
make Hollande's Solution corrosive by themselves, and we have not specifically tested for the cumulative effect of
10/26/2006

<<<PAGE 4>>>

Page 2 of 2
tollande's Solution, we do not believe Hollande's Solution is a 6.1 material, nor do we believe it to be a Class 3
ased upon the properties of the pure components, and the concentrations at which they are present ir
material. It is definitely not a 4.2 nor 4.3 material.
UN3265, Corrosive liquid, acidic, organic, n.o.s. (Formaldehyde, Picric Acid), 8, III
Therefore, we believe that the most appropriate transport classification for Hollande's Solution to be
assification for Hollande's Solution. As always, we appreciate your assistance in keeping Fisher Scientific ar
gain, Fisher Scientific is requesting a formal interpretation regarding the acceptability of this as a transpo
our affiliated companies safely in compliance. Thank you.
Cheers,
Gene Sanders, DGSA
Dangerous Goods Transportation Specialist
2000 Park Lane
Fisher Scientific International, Inc.
Pittsburgh, Pa. 15275 USA
412/490-8934, cell 412/498-2458, fax 412/490-8930
Gene.Sanders @ Fishersci.com
-;==;
MSDS.pdf>>
<<InterpLetter 2000 low percent picric.pdf>> <<InterpLetter 2004 Bouins.pdf>> <<Hollande's solution
10/26/2006

## Provenance

- Official: Yes
- Source: <https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2006/060244.pdf>
- Source ID: `phmsa`
- SHA-256: `75bd7a060dfd53dc5a3996bfde790fa0151572fa8708ada89133e0c31c67aa64`
- Retrieved: 2026-08-20T00:59:31.977Z
- Exported: 2026-08-23T22:17:22.387Z
- Document slug: `phmsa-interpretation-06-0244`

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