{"operation":"document","citation":"07-0101","title":"Degussa Corporation — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2007-07-11","effective_on":null,"summary":"07-0101 response to Degussa Corporation concerning 172.101, 173.22.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-07-0101.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-07-0101.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-07-0101","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2007/070101.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\n1200 New Jersey Avenue, SE\nWashington, D.C 20590\nPipeline and Hazardous\nMaterials Safety Administration\nJUL 1 1 2007\nMr. John Foglio\nDegussa Corporation\n379 Interpace Parkaay\nParsippany, New Jersey 07054-8042\nRef. No.: 07-01 01\nDear Mr. Foglio:\nThis is in response to your May 9, 2007 letter regarding the applicability of the\nHazardous Materials Regulations (HMR; 49 CFR Parts 171-1 80) to the transportation of\nacetone cyanohydrin. Specifically, you request clarification of a previous letter of\ninterpretation issued to you by this office on March 16, 2007 (Ref. No.: 07-0046), which\nstated that the proper shipping name \"Acetone cyanohydrin, stabilized is not an\nappropriate proper shipping name for your material because the material does not meet\nthe definition of an ir?halation hazard. Based on the information you provided at that\ntime, we recommended using the generic proper shipping name, \"Toxic liquid, organic,\nn.0.s.\" In your follolx-up request for interpretation you have added that the material is a\nnitrile with a dermal toxicity of 17 mglkg. Based on the additional information, you ask\nif it is more appropriate to use the proper shipping description \"UN 3276, Nitriles Toxic\nLiquid. n.0.s.. 6.1, P(J I.\"\nAs you are aware. it is the shipper's responsibility to properly class and describe a\nhazardous material. This office does not perform that function. However. based on the\ntechnical data you originally submitted and the additional information you provided in\nthis follow-up letter, it is the opinion of this office that \"Nitriles toxic liquid, n.0.s.. 6.1.\nPG I\" is a more appropriate proper shipping description for your material.\nI hope this information is helpful. If you have further questions. please do not hesitate to\ncontact this office.\nSincerely.\nA /& Chief. Standards Development\nI Office of Hazardous :\\/laterials Standards\n\n<<<PAGE 2>>>\n\nEichenlaub\n$172.101\ndegussa.\n$173.22\nClassitication\n07-0101\nDEGUSSA CORPORATION\nPARSIPPANY, NJ 07054-0677\n379 INTERPACE PARKWAY\nPHONE: DIRECT: (973) 541-8042\nFAX: (973) 541 - 8040\nMay 9, 2007\njohn.foglio@degussa.com\nStandards Development, PHH-11\nOffice of Hazardous Materials Standards\nPipeline and Hazardous Materials\nSafety Administration,\nU.S. Department of Transportation\n1200 New Jersey Ave SE\nWashington, DC 20590-0001\nRe: Acetone Cyanohydrin\nDear Mr. Gale,\nWe would like to thank you for your letter of guidance dated March 16, 2007, copy attached for\nyour convenience. Under the circumstances, we know that your letter will have to be presented\nto carriers and perhaps also to enforcement personnel. We know that any discrepancy in our\nclassification and the one in your letter is likely to present confusion.\nIn your letter you suggested Toxic Liquids, Organic, N.O.S. and PG II. At the time you had no\nway of knowing this is a Nitrile. Also, our references mention that the dermal toxicity is 17 mg /\nkg. We would like to classify the material as UN 3276, Nitriles Toxic Liquid, N.O.S., 6.1, PG I.\nWe know that we are responsible for the classification of material we offer for transportation but\nwe really need your confirmation because as stated above we know we will have to provide your\nletter. Our shipping description will include the generic name acetone cyanohydrin and our\nclassification will be questioned. When we provide your letter our classification as Nitriles will\nnot be supported.\nCan you please send us another letter similar to the other that supports our classification as\nNitriles and PG I? I thank you in advance for your kind assistance.\nSincerely,\nIt Fishin","truncated":false,"body_characters":3616}