Liquid Asborbed in a Filter
Pipeline and Hazardous Materials Safety Administration · Jul 1, 2003 · Reference No. 03-0002
Interprets: 49 CFR § 172.101, 49 CFR § 173.152
This is in response to your letter regarding the description of "waste organic peroxide, Type F, (cumene hydroperoxide) 5.2, UN3109, PG II" under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).
Your letter states that the cumene hydroperoxide has a concentrated mass of 90% and a diluent mass of 10% and the cumene hydroperoxide liquid is totally absorbed in a filter substance that is compatible with the product. You ask whether this material should be described on the shipping paper as a "liquid" or a "solid". In your opinion, "liquid" better describes the material even though the liquid is totally absorbed in the filter substance.
Based on the information contained in your letter, it is our opinion that the material should be described as a "solid" if no free flowing liquid is Visible surrounding the filter substance. Therefore, for a waste material, a shipping name that appropriately describes the material is "Waste organic peroxide, solid, type F, (filter cartridges containing absorbed cumene hydroperoxide), 5.2, UN3110, PG II."
A letter of interpretation applies the regulations to the facts the requester described. It isn’t a regulation and isn’t legal advice. The agency’s copy.