{"operation":"document","citation":"04-0195","title":"General Hydroponics — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2005-06-13","effective_on":null,"summary":"04-0195 response to General Hydroponics concerning 172.101, 172.102.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-04-0195.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-04-0195.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-04-0195","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2004/040195.pdf","body":"<<<PAGE 1>>>\n\n400 Seventh Street, S.W.\nWashington, D.C. 20590\nPipeline and\nJUN 13 2005\nHazardous Materials Safety\nAdministration\nMr. Cal Herrmann ScD\nRef No.: 04-0195\nConsulting Chemist\nGeneral Hydroponics\nP.O. Box 1576\nSebastopol, CA 95473\nDear Mr. Cal Herrmann:\nThis responds to your December 15, 2004 letter requesting clarification of the Hazardous\nfor hydroponic plant growth. Specifically, you ask if the products described in your letter are\nMaterials Regulations (HMR; 49 CFR Parts 171-180) for plant nutrient products that are sold\nsubject to the HMR. You provide the following two product descriptions:\n1) Aqueous solution of inorganic minerals containing less than 10% Nitrates.\n2) Dry mixtures of inorganic minerals containing calcium nitrate and ammonium nitrate,\nwith less than 10% ammonium nitrate and at least 12% water of crystallization.\nIn accordance with § 173.22 of the HMR, it is the shipper's responsibility to determine the\nhazard class of a material offered for transportation in commerce. This office does not\nperform that function.\nSpecial Provision 58 (see § 172.102) provides an exception for aqueous solutions of Division\n5.1 inorganic solid nitrate substances when the concentration of the substances in solution at\nthe minimum temperature encountered in transport is not greater than 80% of the saturation\nlimit. Your product is not subject to the HMR if it meets Special Provision 58 and does not\nmeet the definition of any other hazard class listed in § 173.2.\nSpecial Provision 34 (see § 173.102) provides an exception for commercial grade calcium\nnitrate fertilizer, when consisting mainly of a double salt (calcium nitrate and ammonium\nnitrate) containing not more than 10 percent ammonium nitrate and at least 12 percen: water\nof crystallization. Your product is not subject to the HMR if it meets Special provision 34\nand does not meet the definition of an other hazard class listed in § 173.2.\nI hope this information is helpful. Please contact us if you require additional assistance.\nSincerely\n172.101\n172.102\nOffice of Hazardous Materials Standards\n040195\n\n<<<PAGE 2>>>\n\nExchenlaub\nOffice of Hazardous Materials Standards,\n3172.101\nResearch and Special Programs Administration,\n§ 172. 102\nAttn: DHM10\nU.S. Department of Transportation\n400 7th Street SW\nProper Shipping Name\nWashington, DC 20590-0001\n04-0795\nDec 15, 2004\nTo whom it may concern:\nPursuant to CFR 49 105.20 we are requesting information on applicability of DOT\nregulations concerning shipping some of plant nutrient products that are sold for\nhydroponic plant growth. They are individually packaged in 1 to 5 pound or quart to\nitem containers.\ngallon containers meeting the defined container requirements, and boxes of several\nSpecifically we need to know if we understand correctly as it relates to our products\nit contain nitrates. We ship products that contain nitrates in two forms. They are:\nAqueous solutions of mixtures of inorganic minerals containing less than 10%\nNitrates. We think these products could be classified as - Nitrates, Inorganic,\nunder code 58 of 172.102.\naqueous solution, n.o.s., and exempt from the 5.1 shipping regulations as defined\nDry mixtures of inorganic minerals containing calcium nitrate and ammonium\nnitrate and with less than 10 percent ammonium nitrate and at least 12% water of\ncalcium nitrate and under code 34 of 172.102 be exempt from 172.101.\ncrystallization. We think that these products could be classified as containing\nPlease advise us if our assumptions are correct or not in this matter.\nCal Herrmann ScD\nConsulting Chemist\n707-824-9376","truncated":false,"body_characters":3593}