SC Johnson Wax Professional — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation 400 Seventh Street, S.W. Washington, D.C. 20590 Research and MAR 17 2000 Sciministrarions Ms. Laura Bridges Sr. Packaging Engineer Ref. No. 00-0022 SC Johnson Wax Professional 8310 16th Street Sturtevant, WI 53177-0902 Dear Ms. Bridges: This is in response to your letter dated January 8, 2000, requesting clarification on the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180. letermining whether a Class 8 (corrosive) liquid is organic o1 Specifically, you ask that wher inorganic, Is it appropriate to consider only those components that cause the material to be corrosive, or to base the determination on the whole mixture (i.e., a corrosive liquid and the remainder being water). When determining whether shipper must make that determination based on the hazardous a mixture is organic or inorganic, a components in the mixture. Therefore in your situation, the shipping description should reflect the corrosive constituent in the mixture or solution. I hope this information is helpful. If we can be of further assistance, please contact us. Sincerely, Hatte 2 Michell Hattie I. Mitchell, Chief Regulatory Review and Reinvention Office of Hazardous Materials Standards 000022 173.22 -#

Page 2Beas $173.22. UP™ 00 - 0022 1/8/2000 US Department of Transportation Office of Hazardous Materials Standards Research and Special Programs Administration Mr. Ed Mazzulo 400 Seventh Street, S.W. Washington, DC 20590 Dear Mr. Mazzulo: When determining whether a material, classified as a "Corrosive Liquid," is organic or corganic, is it apropriate to consider only those components that cause the material to bev , or to base the determination on the whole "mixture" (i.e. the complete formula)? Thank you for your time and consideration. Sincerely, Laura Bridges Sr. Packaging Engineer Johnson wax Professional#