Shane Havoc Consulting, LLC — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department Washington, D.C. 20590 400 Seventh St., S.W. special Programs Research and OCT 28 2004 Administration Gregory Sutherland, Ph.D. Ref. No.: 04-0225 Shane Havoc Consulting, LLC 1905 English Ivy Court Mt. Pleasant, SC 29464 Dear Dr. Sutherland: clarification of the requirements for inclusion of This is in response to your September 22, 2004 letter requesting a technical name for a hazardous material described as "Corrosive liquid, acidic, organic, n.o.s." under the Hazardous Materials if "(contains organic acids)" is an acceptable technical name in Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask accordance with $ 172.203 (k). name" means The answer is no. As defined in § 171.8 of the HMR, "technical a recognized chemical name or microbiological name currently used in scientific and technical handbooks, journals, and texts. A chemical description is authorized for use as a technical name provided it readily identifies the general chemical group. Examples of acceptable generic chemical descriptions are "organic phosphate compounds" and "aqueous amino silane polymer." I hope this information is helpful. Please contact us if you require additional assistance. Mile x mitchel Hattie L. Mitchell Office of Hazardous Materials Standards Chief, Regulatory Review and Reinvention 111.8 040225 112.203 (к)#

Page 2Pollack September 22, 2004 $171,8 §172-203 (к) Mr. Ed Mazzullo U.S. Department of Transportation Office of Hazardous Materials Standards Technical Name 400 Seventh Street, SW Washington, DC 20590 04-0225 Dear Sir, I have a client that uses the following as a proper shipping name for an N.O.S. description; Corrosive liquid, acidic, organic, n.o.s. (Contains Organic Acids) They are stating that under 172.203 (k) and the definition of Technical Name in 171.8, they are allowed to use a generic group name rather than a specific Organic acid name. This position is being questioned by ocean carriers that state; "They cannot look up Organic Acids in a standard reference text." They are requesting a specific Organic Acid be listed. I understand the client's position to disclose as little as possible about their formulas for proprietary reasons. I also understand the carriers need to review what they are transporting. The MSDS the client issues does not disclose the specific Organic acid. What I need is a DOT ruling on if Organic Acids is an authorized generic group that can be used as a technical name. Please send your interpretation to: Shane Havoc Consulting, LLC 1905 English Ivy Ct. Mt. Pleasant, SC 29464 Gregory Sutherland Ph.D. (DGSA) If you need any further clarification to my questions please give me a call at: 843-849-1463 Sincerely, Gregory Sutherland#