Dangerous Goods and Cargo Security Division — Hazardous Materials Safety Interpretation

Page 1Memorandum of Transportation U.S. Department Research and Administration Special Programs Date JUN 2 2000 Reply to AtHl. of: Ref. No. 00-0129 …..." Subject: INFORMATION: Request for Interpretation of Classification of Hazardous Material From Edward T. Mazzila, rector Office of Hazardous Materials Standards, DHM-10 To William G. Wilkening Manager, Dangerous Goods and Cargo Security Division, ACO-800 This is in response to your memo dated April 25, 2000, requesting a clarification of the classification and proper shipping description of a solution of 98.7% water and 1.3% picric acid. You enclosed a Material Safety Data Sheet. + Based on the information you provided, it is the opinion of this Office that this solution does not HMR. meet the definition of a hazardous material and; thus, is not subject to the requirements of the # 173.22 000129#

Page 2Memorandum of Transportation U.S. Deparment Administration Federal Aviation Subject ACTION: Request for Interpretation of Date: April 25, 2000 Classification of Hazardous Material rom: Manager, Dangerous Goods and Cargo Security Division, ACO-800 To: Edward Mazzullo, Director, Office of Hazardous Material Standard, DHM-10 I am forwarding an inquiry received in this office requesting an interpretation of the classification of a solution of 98.7% water and 1.3% picric acid. The material safety data sheet for this solution is also provided for your reference. If this office can be of further assistance, please contact us. William G. Wilkening Attachment#

Page 3- Memorandum of Transportation U.S. Department Adminlatrallor Federal Avlation corbin $173.22 Subject: ACTION: RSPA Interpretation Door April 3, 20000-0829 From: DG/CS Program Coordinator, AGL-705 An. 00 To: Research and Special Programs Administration THRU: Dangerous Goods and Cargo Security Manager, ACO-800 I am requesting a formal interpretation from RSPA believed to be regulated as a hazardous material by 49 CFR. concerning the properties of a specific solution that is The solution in question consists of 98.7% water and 1.3% picric acid. material is also provided for your reference. Specifically. The material safety data sheet for this I am requesting to know if the above stated solution of pieric acid is regulated as a hazardous material when offered for transportation in air commerce. If the material is regulated what would be the correct proper shipping name, hazard class, and UN number when offered for domestic air transportation? Suin Abott Brian C. Abbott Attachment#