Classification as Organic or Inorganic
Pipeline and Hazardous Materials Safety Administration · Nov 26, 1996 · Reference No. 96-1019
Interprets: 49 CFR § 172.101
This is in response to your letter requesting confirmation of appropriate generic shipping descriptions for mixtures and lab packs containing both organic and inorganic materials. Your questions are paraphrased and answered as follows:
Q1. What designation takes precedence in a mixture containing both organic and inorganic components? If a mixture has only a small percentage of organic components, and a large percentage of inorganic components, which designation takes precedence?
A1. If a mixture contains equal amounts of organic and inorganic components, the shipping description should reflect "organic." Otherwise, the shipping description should reflect the most abundant component.
Q2. Would "organic" still be appropriate for a lab pack with one small jar of organic material, with the rest of the inner containers having inorganic materials?
A2. No. An appropriate generic or n.o.s. shipping description that does not reflect either "organic" or "inorganic" (e.g., "corrosive liquid, n.o.s.") should be used.
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.