Regulatory Compliance Services — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department Washington, D.C 400 Seventh Street, S.W. 20590 Special Programs Research and Administration SEP 2 5 2000 Mr. Chris Corea Ref. No. 00-0201 Regulatory Compliance Services 6740 Huntley Road Suite 203 Worthington, Ohio 43229 Dear Mr. Corea: This is in response to your letter dated July 20, 2000, requesting clarification on the proper shipping name for denatured alcohol under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). In your letter you reference "Flammable liquids n.o.s., 3, UN1993," and "Alcohols, n.o.s., three shipping names: "Ethanol solutions, 3, UN1170, " 3, UN1987." Specifically, you asked which shipping name is most appropriate for a denatured alcohol. Under $ 173.22, it is the shipper's responsibility to properly classify a hazardous material and assign it a proper shipping name from the Hazardous Materials Table (HMT). For a material not specifically identified by name in the HMT, the HMR requires that the material be described by the shipping name that "most appropriately describes" the material. In some cases, more than one shipping name could "most appropriately describe" a material. However, it is the opinion of this Office that the shipping name "Ethanol solutions" most appropriately describes denatured alcohol. I hope this satisfies your request. Sincerely, Delmer E. Billings Chief, Standards Development Office of Hazardous Materials Standards 172:101(c) 000201#

Page 2REGULATORY COMPLIANCE SERVICES BAH §172-101(c) .C..C..2:1 July, 20, 2000 Mr. Edward T. Mazzullo U.S. DOT/RSPA (DHM-10) Director, Office of Hazardous Materials Standards 400 7th Street S.W. Washington, D.C. 20590-0001 RE: Proper Shipping Description of Denatured Ethano/ Dear Mr. Mazzullo, Denatured Alcohol. This letter is a request for interpretation regarding the proper shipping description of During my course of research, the three descriptions found most in industry are the following: "Ethánol Solutions, 3, UN1170" or "Flammable Liquids n.o.s., 3, UN1993" "Alcohols, n.o.s., 3, UN1987" From the selections, I can understand the reasoning behind the three: Ethanol Solutions - the majority of the product is composed of Ethanol with approximately 5 percent of Isopropanol and/or Methanol. Since the product is not entirely composed of Ethanol, the "Ethanol Solutions" designation is used as the proper shipping description. Flammable Liquids n.o.s. - although the majority of the product is Ethanol, the other constituents (Isopropanol and/or Methanol) contribute to the overall hazard or flammability. As such the designation of a "Flammable Liquid, N.O.S." seems an accurate shipping description. Alcohols, n.o.s. - ail constituents found in the product are alcohols (ethyl alcohol, methy! alcohol, isopropyl alcohol). As such, this description seems to accurately describe the material because they all contribute to the hazard any interpretation that can be provided would be greatly appreciated. If you have any further Denatured alcohol is a hazardous material prevalently used throughout all of industry and questions or concerns regarding this issue, please do not hesitate to contact me at the office at (614) 888-8825 ext. 14. Thank you for your anticipated cooperation. Very Tryly Your Chris Corea Senior Technical Consultant - RCS, Inc. 6740 HUNTLEY ROAD - SUITE 203 WORTHINGTON, OHIO 43229 PHONE: (614) 888-8825 FAX: (614) 841-1372#