{"operation":"document","citation":"13-0135","title":"Patterson Companies, Inc. c/o Patterson Logistics Services, Inc — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2013-07-03","effective_on":null,"summary":"13-0135 response to Patterson Companies, Inc. c/o Patterson Logistics Services, Inc concerning 173.22.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-13-0135.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-13-0135.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-13-0135","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2013/130135.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n1200 New Jersey Avenue, SE\nWashington, DC. 20590\nJUL 0 3 2013\nMr. Robb Boros\nPatterson Companies, Inc.\nc/o Patterson Logistics Services, Inc.\nI 905 Lakewood Drive\nBoone, IA 50036\nRefNo.: 13-0135\nDear Mr. Boros:\nThis is a response to your June 24, 2013 email requesting clarification of the Hazardous\nMaterials Regulations (HMR; 49 CFR Parts 171-180) with regard to the selection of a proper\nshipping name. Specifically, you seek clarification on whether you may use the hazardous\nmaterials description \"UN1266, Perfumery products,\" for a product used as a disinfectant or\ncleaner and not as a perfume.\nIn accordance with § 173.22, it is the shipper's responsibility to properly class and describe a\nhazardous material. This Office does not perform that function. There is no definition for\n''perfumery products\" in the HMR. However, perfume is typically defined as a f1uid\npreparation used for scenting, composed of natural essences or synthetics and a fixative.\nGiven that the primary function of your product is not as a perfume, but rather, a product\nintended to be used as a disinfectant or cleaner, the description the description of\"UN1266,\nPerfumery products\" would not be appropriate.\nI hope this information is helpful. If you have any more questions, please do not hesitate to\ncontact this office.\nSincerely,\n7~~~\nRobert Benedict\nChief, Standards Development\nStandards and Rulemaking Division\n----------------\n--------------\n\n<<<PAGE 2>>>\n\n5u~k.\n~ J1 /. 8\nDrakeford, Carolyn (PHMSA) § 17'2>, l 0 J\nI\nFrom:\nINFOCNTR (PHMSA) De-Pi() i h Or15\nSent:\nTo: Drakeford, Carolyn (PHMSA) I 3-0£3\nMonday, June 24,2013 4:30PM 5\nSubject: FW: Latter requesting interpretation regarding the definition of Perfumery product.\nHi Carolyn,\nThis caller requested we submit this e-mail as a formal letter of interpretation.\nThanks,\nVictoria\nFrom: robb.boros@pattersoncompanies.com [mailto:robb.boros@pattersoncompanies.com]\nSent: Monday, June 24, 2013 1:41PM\nTo: INFOCNTR (PHMSA)\nSubject: Latter requesting interpretation regarding the definition of Perfumery product.\nAccording to Dictionary.com a perfume is a substance, extract, or preparation for diffusing or imparting an agreeable or attractive\nsmell, especially a fluid containing fragrant natural oils extracted from flowers, woods, etc., or similar synthetic oils.\nIn order for a material to be eligible to use the shipping description Perfumery product, UN1266 would its primary end-use\nfunction need to meet the definition referenced above for perfume?\nWould a material that meets the definition of a flammable liquid, where the a material with a primary function not described\nas a perfumery product , such as a cleaner or disinfectant, be eligible to use shipping description Perfumery products,\nUN1266?\nThanks\nRobb Boros\nRegulatory Compliance Specialist\nPatterson Companies, Inc.\n515.433.1700 (Fax 1701)\nNOTICE: This email transmission and any attachments that accompany it may contain information that is confidential or\notherwise exempt from disclosure under applicable law and is intended solely for the use of the individual(s) to whom it was\nintended to be addressed. If you have received this email by mistake, or you are not the intended recipient, any disclosure,\ndissemination, distribution, copying or other use or retention of this communication or its substance is prohibited. If you\nhave received this communication in error, please immediately report to the author via email that you received this message\nby mistake and also permanently destroy printed copies and delete the original and all copies of this email and any\nattachments from your computer.\n1","truncated":false,"body_characters":3724}