PHMSA letter of interpretation

Classification Potassium Hydroxide and Hydroquinone

Pipeline and Hazardous Materials Safety Administration · Sep 1, 1994 · Reference No. 94-0102

PHMSA says to use caution with this letter.

Interprets: 49 CFR § 173.22

Reggie’s quick take

Someone asked PHMSA how to ship a solution containing potassium hydroxide and hydroquinone. The agency said the shipper is responsible for classifying the material under § 173.22, and that it does not usually do that job itself. It also said safety data sheets are not required by the rules and often do not help with classification. Based on the information provided, PHMSA agreed that "Corrosive liquid, n.o.s. (potassium hydroxide), 8, UN1760, PG II" is the correct proper shipping description for that material.

Written by AI (Claude) on Oct 22, 2026. Robots make mistakes and leave things out, so the letter below is what counts. Not legal advice.

This is in response to your letter regarding a shipping description for a solution containing potassium hydroxide and hydroquinone. I apologize for the delay in responding to your inquiry and hope it has not caused you any inconvenience.

Under 49 CFR 173.22, it is the shipper's responsibility to properly classify a hazardous material. This office does not generally perform this function. Also, material safety data sheets are not required by the Hazardous Materials Regulations (49 CFR 171-180) and often they are not of use in determining the classification of a hazardous material. However, based on the information submitted. in our opinion, we agree that "Corrosive liquid, n.o.s. (potassium hydroxide), 8, UN1760, PG II" is the correct proper shipping description for the material described.

If we can be of further assistance, please feel free to contact us.

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.