Uniroyal Chemical Company, Inc. — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department Washington, D.C. 400 Seventh Street, S.W. 20590 Research and Special Programs Administration SEP - 8 1999 Mr. Donald Hodder Ret. NO - 99-0219 Global HAZMAT Compliance Manager Middlebury, CT Uniroyal Chemical Company, Inc. 06749 Dear Mr. Hodder: This is in response to your letter dated July 30, 1999, regarding the selection of a proper shipping name under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). In your letter, you request clarification on the proper shipping name for a mixture containing various ranges of as "Dyes, liquid, corrosive, n.o.s. (Acetic Acid);" however, acetic acid. You stated the material is currently described solution." you would like to use the proper shipping name "Acetic acid Under § 173.22, it is the shipper's responsibility to properly class and describe the material. information you provided, it is our determination that either However, based on the proper shipping name would be correct for the mixture. I hope this satisfies your request. Sincerely, Transportation Regulations Specialist Office of Hazardous Materials Standards 990219 172.101 173.22#

Page 2CHEMICAL UNIROYAL World Headquarters Uniroyal Chemical Company, Inc. (203) 573-3702 Middlebury, CT 06749 July 30, 1999 BAH- 13.22 Mr. Edward Mazzullo U.S. Department of Transportation 99-0219 Hazardous Materials Standards 400 Seventh Street S.W. Washington, DC 20590 Subject: Selection of a Proper Shipping Name for a Mixture and Solution Dear Mr. Mazzullo: Name or severany is having a d: The mento consin Actic a Pin var Shipping percentage ranges. Based on the information in § 172.101(c)(10)(i)(E) the material is currently called "Dyes, liquid, corrosive, n.o.s. (Acetic acid)". The above section starts as follows: "A mixture or solution not identified specifically by name" Because of this wording, I feel that the Proper Shipping Name should be "Acetic acid solution" which is specifically identified by name in the Hazardous Materials Table. Please review the above information and advise the correct interpretation of this section so that we show the correct Proper Shipping Name for this product line. Your contact me at 203-573-3702. assistance in this matter is appreciated. If you need any additional information you can Sincerely; fected Donald Hodder Global HAZMAT Compliance Manager CC: Janice Warnquist#