Guidanceguidance
01-0239
T. Hasegawa USA Inc. — Hazardous Materials Safety Interpretation
Current as of source date Government source
RegulusPipeline researchRegulusPipeline research01-0239
Page 1of Transportation U.S. Department Washington, D.C. 20590 400 Seventh St., S.W Research and Special Programs Administration OCT ***5 2001 Mr. Sean F. Surbeck Ref. No. 01-0239 14017 E 183rd Street T. Hasegawa USA Inc. St. Cerritos, CA 90703 Dear Mr. Surbeck: This is in response to your letter dated September 5, 2001, apple cinnamon flavor with a flash point of 70°C (158°F) requesting clarification on whether your natural and artificial regulated under the Hazardous Materials Regulations (HMR; 49 CER Parts 171-180). 'Under $ 173.22, it is the shipper's responsibility to properly classify a hazardous material. This office generally does not perform this function. Under $ 173.120, combustible liquid is defined as a material with a flash point above 60.5°C (141°F) and below 93°C (200°F), and does not meet the definition of any other hazard class under the HMR. Therefore, in accordance with the HMR, your natural and artificial apple cinnamon flavor is classed as a (450 L or less) packaging is not subject to any requirements combustible liquid. under the HMR, including labeling; unless the material is a hazardous waste, hazardous substance or marine pollutant. I hope this satisfies your request. Sincerely, Transportation Regulations Specialist Office of Hazardous Materials Standards - 010239#
Page 2• 12/2901_89:18 7145226625 T HASEGAWA LAB BAN •PAGE Ø1 Edmonsoo §|73. 120 Classification 01-0239 T. HASEGAWA USA INC. flavors | fragrances 14017 East 183° St, Cerritos, CA 90703 | 714.522.1900 | FAX 714.522.5625 FAX To: Edward Mazzullo From: Sean F. Surbeck Co: DOT Phone: 714.522.1900 Phone: 800.467.4922 Date: Wednesday, September D5, 2001 Fax: 202.366.3012 Pages: 3 Including cover X Urgent • For Review • Please Comment XPlease Reply • Per Your Request • Comments: we categorize materials on our MSDS according to the DOT. We have listed a Due to a complaint from one of our customers, we are requesting clarification on how material with a flash point of 70°C as DOT: Class 3 Combustible Liquid. According to our customer we are misrepresenting this item due to the inclusion of the words "Class 3." Wednesday, September 12, 2001 | spoke with DOT employee, Cameron to check the accuracy of our MSDS. According to Cameron we are correct in listing this product under Class 3, A flash point of 70°C is under definition of Class 3." Could you please confirm this in writing. I have attached our MSDS for this product and a copy of our internal flow chart to show you how we determine the appropriate DOT label for our materials on our MSDS. Please feel free to contact me if you have any questions. Jensibil Thank you, 10c. Sean F. Surbeck Food Technologist/R&D Applications ssurbeck@thasegawa.com -#
This material provides agency context. It does not replace binding regulatory text, and its legal effect depends on the underlying authority and facts.