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December 16, 2022: PHMSA Addresses Clarification Request on Proper Shipping Names

PHMSA received a letter in May 2022 requesting clarification on proper shipping names (PSN). The letter, submitted by Rinchem Company, Inc., provided the following example when asking if the shipper could use both names at the same time for the shipping description: 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.
PHMSA explained the intent of the shipping description requirements is to include one PSN that most appropriately describes the material. It provides as an 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, the agency went on to say that “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. As a result, it is 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 property shipping name and hazard class or following the basic description.” It cites in support 172.202(d).

Interpretation Response #22-0040

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