DRMO-Luke — Hazardous Materials Safety Interpretation

Page 1".' U.S. Department of Transportation Washington, D.C. 400 Seventh Street, S.W. 20590 Special Programs Administration MAY * § 1998 Bef. No. 98-0014 Mr. Eddie Ellis Environmental Protection Specialist DRMO-Luke 7011 N. El Mirage Rd. Glendale, AZ 85307-2503 Dear Mr. Ellis: This is in response to your letter of March 10, 1998, concerning the use of abbreviations as technical names under the Hazardous Materials Regulations (49 CFR; Parts 171-185). Specifically, you asked if the abbreviation "MEK" may be used as a technical name for a hazardous material. The abbreviation "MEK" may be used as a technical name for the chemical methyl ethyl ketone to meet the requirements of § 172.203(k). The definition in § 171.8 of "technical name" means a recognized chemical name or microbiological name currently used in scientific and technical handbooks, journals and texts. This abbreviation, however, may not be used as a proper shipping name as it does not appear specifically listed in the Hazardous Materials Table in § 172.101. I hope this answers your question. If we can be of further assistance, do not hesitate to contact us. Sincerely, Office of Hazardous Materials Standards#

Page 2• / 'R. - 10'98 (TUE) 14:20 DRMO LUKE TEL: 602 856 Yet nachos P. 001 - - I'le: 172.203 (K) DEFENSE LOGISTICS AGENCY DEFENSE STUZAN AND MARKETING DENCE 50% GLENDALE, AZ 85307-2503 7011 N. EL MIRAGE RD. ANKURANT DRMO Luke-UHA 10 Mar 98 MEMORANDUM FOR DEPARTMENT OF TRANSPORTATION ATTN: MIKE JOHNSON SUBJECT: Request for Interpretation The question is: "Can the abbreviation "MEK" be used as the technical name of the hazardous material that must be entered in parentheses in association with the basic description of a shipping paper?" (Reference 172.203(K)) Example: Flammable Liquids, N.O.S. (MEK & Toluene) The abbreviation for Methyl Ethyl Ketone is found in 49 CFR, 172.101, Table 1, "Hazardous Substances other than Radionuclides", Hawley's Condensed Chemical Dictionary, Eleventh Edition; 40 CFR PT 264, App IX "Ground Water Monitoring List", 40 CFR 261.33 EPA Hazardous Waste Number U159; Sax's Dangerous Properties of Industrial Materials, Eighth Edition, as a synonym (MKA 400); Chris Hazardous Chemical Data M.16465.12A, listed as a common synonym. The list is endless as every technical publication identifies MEK as a synonym of methyl ethyl ketone. It is understood that the abbreviation cannot be used as a proper materials description and proper shipping name as listed in 172.101. Please provide your interpretation to us by fax as soon as possible. Our fax number is (602) 856-7146 and telephone (602) 856-7144. Thank you for your assistance in this matter. EDDIE ELLIS Environmental Protection Specialist DRMO Luke#