Rinchem Company, Inc — Hazardous Materials Safety Interpretation

Page 11200 New Jersey Avenue, SE Washington, DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration October 3, 2022 Joe Strelow Operations Manager Rinchem Company, Inc 917 Lone Oak Rd, Ste 100 Eagan, MN 55121 Reference No. 22-0040 Dear Mr. Strelow: This letter is in response to your May 3, 2022, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to proper shipping names (PSNs). Specifically, you provide the example of “UN1219, Isopropanol or Isopropyl alcohol, 3, PG II” where Column (2) of the § 172.101 Hazardous Materials Table (HMT) lists both “Isopropanol” and “Isopropyl alcohol” in Roman type as PSN alternatives. You ask whether a shipper may use both—at the same time—for the shipping description of a hazardous material required by § 172.202 or whether the intent is to use only one at a time. The intent of the shipping description requirements is to include the one PSN that most appropriately describes the material. For example, for “UN3164, Articles, pressurized pneumatic or hydraulic containing non-flammable gas, 2.2” the selected PSN must indicate whether the article is pneumatic or hydraulic—it cannot be both. However, in the instance of “UN1219, Isopropanol or Isopropyl alcohol, 3, PG II, ” the PSN alternatives are variations of the chemical name that describes the material itself.#

Page 2In such a case, it would be permissible to show the PSN as one of the alternatives with the other as a chemical or technical group name in parentheses either between the proper shipping name and hazard class or following the basic description—see § 172.202(d)—as such a scenario still accurately describes the material. For example: • UN1219, Isopropanol (Isopropyl alcohol), 3, PG II • UN1219, Isopropyl alcohol (Isopropanol), 3, PG II I hope this information is helpful. Please contact us if we can be of further assistance. Sincerely, Dirk Der Kinderen Chief, Standards Development Branch Standards and Rulemaking Division#

Page 3Cardez 22-0040 Request for Formal Letter of Interpretation Date: May 3, 2022 Mr. Shane Kelley Director, Standards and Rulemaking Division U.S. DOT/PHMSA (PHH-10) 1200 New Jersey Avenue SE, East Building, 2nd Floor Washington, DC 20590 Dear Mr. Kelley, I am requesting clarification and a formal interpretation on 49 CFR 172.101(c)(2). The rule states: The word “or” in italics indicates that there is a choice of terms in the sequence that may alternately be used as the proper shipping name or as part of the proper shipping name, as appropriate. For example, for the hazardous materials description “Carbon dioxide, solid or Dry ice” either “Carbon dioxide, solid” or “Dry ice” may be used as the proper shipping name; and for the hazardous materials description “Articles, pressurized pneumatic or hydraulic,” either “Articles, pressurized pneumatic” or “Articles, pressurized hydraulic” may be used as the proper shipping name. Does the use of or in this rule prohibit the use of both proper shipping names together for one material? For instance, the proper shipping name for UN 1219 is Isopropanol or Isopropyl alcohol. Is it appropriate for this material to be listed as any of the following? UN 1219, Isopropanol (Isopropyl alcohol), 3, PG II, ERG: 129 UN 1219, Isopropyl alcohol (Isopropanol), 3, PG II, ERG: 129 Must a shipper use only one or the other proper shipping name, or can both names be used as shown? Thank you for your attention and I look forward to your response. Joe Strelow Operations Manager Rinchem Company, Inc 917 Lone Oak Rd, Ste 100 Eagan, MN 55121#