# Mr. Lawrence W. Bierlein — Hazardous Materials Safety Interpretation **Citation:** 01-0234 **Type / status:** guidance / guidance **Agency:** Pipeline and Hazardous Materials Safety Administration **Effective:** Not stated **Published:** 2001-01-23 01-0234 concerning 173.136. ## Document text <<>> • • CONCURMENCES : JAN 2 3 2001 Mr. Lawrence W. Bierlein RIG. SYMBOT 2175 K Street, NW Washington, DC 20037 Dear Mr. Bierlein: On September 1, 2000, on behalf of Hewlett-Packard Company, you applied for an approval to RIG SYMBOL ship certain inkjet cartridges as unregulated materials. This is in response to your subsequent letter of January 5, 2001, enclosing results of certain steel corrosion tests and a comparative chart on steel compositions. We have reviewed that test data and chart, and conclude that the K02400 steel tested is sufficiently "similar to" P3 and P235 steels, as that term is used in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) and the United Nations Model Regulations on the Transport of Dangerous Goods, to be accepted for Class 8 classification purposes. We also BATE conclude, based upon the 14-day test results you provided, that the ink in the Hewlett-Packard inkjet printer cartridges does not meet the definition of a corrosive material as set forth in 49 CFR §§ 173.136 and 173,137, and in international regulations based upon Chapter 2.8 of the UN DHM-30 Model Regulations on the Transport of Dangerous Goods. INTALAKE Accordingly, because the ink is not regulated as a hazardous material, the approval you originally BATE requested is not necessary. 16. 3915801 -L3-0 Sincerely, 1/23/01 Edward T. Mazzullo, Director - SYMBOC Office of Hazardous Materials Standards DLM-20 Mazzullo:gt:dhm-10:68553:01/17/2001 Revised Sireechen File: 173.136 1/23/01 R1a:39M80L DHM-10 • TW .... : /23/01 01-0234 <<>> D CONCUMRENCES "HITULUSKE TATE Mr. Lawrence W. Bierlein 2175 K Street, NW RIE SYNABO Washington. DC 20037 "ЖІТСАЖК) Dear Mr. Bierlein: On September 1,2000, on behalf of Hewlett-Packard Company, you applied for an approval to ship certain inkjet cartridges as unregulated materials. This is in response to your subsequent letter of January 5, 2001, enclosing results of certain steel corrosion tests and a comparative chart on steel compositions. "ВИТЕ" We have reviewed that test data and chart, and conclude that the K02400 steel tested is sufficiently "similar to" P3 and P235 steels, as that term is used in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) and the United Nations Model Regulations on the "STOLUSKE Transport of Dangerous Goods, to be accepted for Class 8 classification purposes. We also conclude, based upon the 14-day test results you provided, that the ink in the Hewlett-Packard inkjet printer cartridges does not meet the definition of a corrosive material as set forth in 49 iT SidES CFR §§ 173.136 and 173.137, and in international regulations based upon Chapter 2.8 of the UN Model Regulations on the Transport of Dangerous Goods. Accordingly, because the ink is not regulated as a hazardous material, the approval you originally TATE requested is not necessary and, as you requested, we are returning the approval application to you. "RIC SEC Sincerely, "TATE™ HIa знает Edward T. Mazzullo, Director DHM 1O Office of Hazardous Materials Standards HITOSKE 47- навалоно 01/19/01 Mazzullo:gt:dhm-10:68553:01/17/2001 REE SYMEL File:173.136 ! 01/17/200 OFFICIAL FRE COPY <<>> OCT-0:-00 13,42 FROMx XD. - PACE • MCCARTHY, SWEENEY & HARKAWAY, P.C. 2175 K Street, N.W. Washington DC 20037 (202) 393-5710 (202) 393-5721 (Fax) lwbierlein@mshpc.com Date: October 1, 2000 To: JIM O'STEEN ED MAZZULLO Fax No.: 366-3753 366-3012 Froma: LARRY BIERLEIN Pages: 9 MESSAGE: FXI - The people at Hewlett-Packard are running tests on their inkjet printer ink in accordance with the two attached test suites. Also attached is test protocol SW-846 Method 1110 on steel corrosion. We think the results will support a revised "quantity and form" approach to an approval. I will let you kaow when the results are in, along with additional info about the ink and its properties. Thanks. <<>> ост-01-00 13,42 FROM. PAGE 2 • Test Suite One 1) Obtain 3 samples of SAE 1020 Steel wilh dimensions of approximately 12"X(2". 2) Prepare surfaces of all saxaples per SW-846 Method 1110 test methods. 3) Simulate as ink spill (using our most aggressive ink) on 2 of the stocl samples (basically, cover tbe entire surface arca with ink). The 3" sample will be used as a control. 5) Measure the dry time. 4) Let the ink dry in standard atmospheric conditions (23C, 60% relative humidity). 6) Clean and measure the corrosivity of 1 of the samples and the control samplo per SW-846 Method 1110 test methods. 7) Let the other sample remain in standard atmospheric conditions (23C, 60% relative bumidity) for au extended period (~1 week). 8) Clear and measure the corrosivity of the 2% sample per SW-846 Method 1110 test methods. 9) Compare the results of all 3 samples relative to each orber and guidelines for corrosion rates (6.35 xampy). 10) Document all results. Test Suite Iwo 1) Obtain 3 samples of SAt 1020 Steel staadard coupons. 2) Preparo surfaces of all samplos per SW-846 Method 1110 test methods. 3) Subject two of the coupons per SW-846 Method 1110 tests methods (using our most aggressive ink) for a period of time equal to the dry time calculated in Test Suite One. The 3" sample will be used as a control. 4) Clean and measure the corrosivity of 1 of the coupons and the control coupon per SW-846 Method 1110 test methods. 5) Let the other coupon remain in standard atmospheric conditions (23C, 60% relative humidity) for an extended period (~/week). 6) Clean aud measure the corrosivity of the 2º% coupon per SW-846 Method 1110 test methods. 7) Compare the results of all 3 coupons relative to each other and guidclines for costosion rates (6.53 mampy). 8) Document all results. <<>> OCT-01-80 13,42 FROM. 1D. PAGE 3 METHOD 1110 CORROSIVLIY TOWARO STEEL 1.O SCOPE AND APPLICATION aqueous and nonaqueous líquia wastes. 1.1 Method 1110 is used to measure the corrosivity toward steel of both 2.0 SUMMARY OF METHOO evaluated and, by measuring the degree to which the coupon has been This test exposes coupons of SAE Type 1020 steel to the liquid waste dissolved, determines the corrosivity of the waste. 3.0 INTERFERENCES is usualdy reproducible to within en as ents one, corrosion of supicate coupons rates may occasionally occur under conditions where the metal surfaces become However. large differences in corrosion should be made. passivated. Therefore, at least duplicate determinations of corrosion rate 4.0 APPARATUS AND MATERIALS suitable size (usually 500 to 5,000 mL). ¿ reflux condenser, a thermowell and An apparatus should be used, consisting of a kettle or flask uf a specimen support systen. A typical resin Mask set up for this type of test temperature regulating device, à heating device (mantle, hot plate. or bath). and is shown in figure 1. The method of supporting the coupons will vary with the apparatus used for conducting the test, but it should be designed to insulate the coupons from actailic container or orner device used in the rest. some common support each other physically and electrically and to insulate the coupons from any materíals include glass, fluorocaroon. or coated metal. with the waste. 4.4 The shope and form of the coupon support should ensure tree contact CO-ROM 2120-1 Revision _0. Date September 1986 <<>> 0CT-01-00 13,42 FROM» ID• PACE 4 -G A- B- -E - D Figure 1. conventent apparatus to conduct simple immersion tests. Configuration of the typical resin flask that can de used as a versatile and the specific test being conducted. rask top is such that more sophisticated apparatus can de dodeo as required by ^ ° thermowell. B - resin flask. C : specinens hung on supporting device. Om heating mantle. E -opening in flask for additional apparatus that may be required. and G- liquid interface. reflux condenser, x CO-ROM 1110 - 2 Revision - Reve Secrenber 1986 <<>> OCT-01-00 13:43 FROM. ID. PAGE diameter is a convenient shape for a coupon. 1.s A circular specimen of SAC 1020 steel of about 3.75 ca (1.5 in.) 0.32 cm (0.125 in.) and a 0.80 c= (0.1-in.) diameter hole for mounting. theso With a thickness of approximately specimens will readily pass through a 45/50 ground-glass joint of a distillation kettle. equation: The total surface area of a circular soccinen is given by the following A -3.14/2(0'-d') + (2) (3.14)(0) + (*) (3.14) (d) where: 0 - diamoter of the specimen. ¿- thickness. o-dianeter of the mounting hole. If the hole is completely covered by the mounting support, the last term in the equation. (E) (3.14)(d), is ovitted. 4.5.1 calculation of the exposed areas. An area calculation accurate to 12% is All coupons should be measured carefully to pernit accurate usually adequate. of metal is removed from the coupons prior to testing the corrosivity of the 4.5.2 More uniform results may he expected if a substantial layer electrolytic removal, or by grinding with à coarse abrasive. At least 0.254 îhis can be accomplished by chemical treatnent (pickling). by should inciude finishing with #120 abrasive paper or cloth. a (0.0001 in.) or 2-3 mg/en? should be renoved. Hinal surface treatment consists of scrubbing with bleach-free scouring powder, followed by rinsing Final cleaning drying. in distilled water and then in acetone or methanol, and finally by air until used. After final cleaning, the coupon should be stored in a desiccator 4.5.3 coupon to he used in this test is 40 mL/cal. The minimum ratio of volume of waste to area of the melal S.O REAGENTS 11 we a Sale daoxia (0). (204): Orsolves 200 g MaCH 1n 800 ML Type 5.2 Zine dust. 5.3 Hydrochieris acid (HCI): Concentrated. 5.4 Stannous chloride (Snch,). 5.5 Antimeny chloride (S0C),). CO-ROM 1110 - 3 late Septemner 198/ revision —e <<>> OCT-01-00 13143 FROM, PAGE 6 * 6.0 SAMPLE COLLECTION, PRESERVATION. AND HANDLING the considerations discussed in Chapter Nine of this manual. 6.1 All samples should be collected using & sampling plan that addresses 7.0 PROCEDURE 2.1 Assemble the test apparatus as deseribed in Paragraph 1.0. above. 1.2 Fill the container with the appropriate anount of waste. 7,3 Begin agitation at a rate sufficient to ensure that the liquid is kept well mixed and homogeneous. (130°7). Using the noating device, Dring the tenperature of the naste to 35°C as to whether the rate of corrosion is less than or greater than 6.35 am per year 7.5" An accurate rate of corrosion is not required: only a determination is required. A 24-hr test period should be ample to detersine whether on not the rate of corrosion is >6.35 ma por year. In order to determine accurately the amount of matertal lost to corrosion, the coupons have to de cleaned after inmersion and prior to weighing. The cleaning procedure should remove ail products of corrosion while removing a minimum of sound metal. Cleaning methóds can be dividea into three general categories: mechanical, chemical, and electrolytic. Mechanical cleaning includes scrubbing, scraping, brushing. and ultrasonic procedures. Scrubbing with & bristle brush and mild abrasive is the most popular of these methods. The others are used in coses of heavy corrosion as a first step in removing heavily encrusted corrosion products prior to scrubbing. Care should be taken to avoro removing sound metal. Chemical cleaning implies the renoval of materíal from the surface of the coupon by dissolution in an appropriato solvent. Solvents grease, or resinous materials ard are used prior to immersion to remove the as acetone, dichloromethane, ane alconol are used to remove un. products of corrosion. Solutions suitable for removing corrosion from the steel coupon are: Solution Seakina time Iemperature 20% NaOIl " 200 g/l zine dust 5 min Betting or conc. 1101=50 8/e such, + 20 gli socl, Until clean cold 1110 - 4 CO-ROM Revision - Date Sentember 1986 : <<>> 067-01-00 13,43 FROM. ID. "PACE 7 rebove looser decerony co rosion preducts. one meted or electroly to cleaning that can be employed uses: soluzion: 50 g/L H,SO. Anode: Carbon or lead Cathode: Steel coupon Cathode current density: 20 amp/ca? (129 arp/in.") inhibitor: 2. ce organic inhibitor/liter ¡emperature: 74 °C (165°5) Exposure Pariod: 3 min. NOLE: Precautions must be taken to ensure good electrical contact with the metal ions and to ensure that inhibitor decomposition has not occurred. coupon to avoid contamination of the cleaning solution with easily reducible Instead of a propriotary inhfoitor, 0.5 g/l of either diorthotolyl chiourea or quinolin ethiodide can be used. removing sound metal should be determined by using a blank (i.e.. a coupon that 1.7 Whatever treatment is employed to clean the coupons. its effect in has not been exposed to the waste). The blank should be cleaned along with the test coupon and its waste loss subtracted from that calculated for the test coupons. reweighed. The weight loss is employed as the principal measure of corrosion. After corroded specimens havo been cleaned and dried. they are Use of weight loss as a measure of corrosion requires making the assumption that in order to determine the corrosion rate for the purpose of this regulation. the all weight loss has been due to generalized corrosion and not localized pitting. following formula is used: ¡orrosson Rate (ampy) - Weight loss × 11.34 rer x rig where: weight loss is in milligrams. area in square centimeters. time in hours, and corrosion rate in sillineters per year (rapy). 8.0 QUALITY CONTROL 8.1 All qualsty control data should be filled and avallable for auditing. 8.2 Duplicate samples should be analyzed on a routine basis. CO-ROM 1110 - 3 Revision - Date September 1986 <<>> OCT- 01-00 13x43 FROM. XD " PAGE 8 9.0 METHOD PERTORMANCE 9.1 No data provided. 10.0 REFERENCES 1. National Association of Corrosion Engineers. "Laboratory Corrosion Testing NACE, 3400 West Loop South, Houston. IX /7027. of Metals for the Process Industries." NACE Standard TM-01-69 (1972 Rovision). CO-ROM 1110 - 6 Revision _e Date Sentenner 1986 <<>> OCT-01-00 13144 FROM, PAGE 9 CORROSIVITY TOWARD STEEL METHOD 1110 Start ress apparatus. 7.1 Assemble 7.6 Clean coupons chemical, and/or by mechanical. electrolyric methods. 7.2 Fill container 7.7 Check eftect with waste. treatment on of cleaning removing sound metal. 7.3 Agirare. 7.8 Determin ¡orrosion rare 7.4 Heat. StOP CO-ROM" 1110 ÷ / Date Revision Serener 1986 <<>> Mazzullo. Ed From: Iwbierlein(iwbierlein@mshpc.com/ Sent: Monday, January 22, 2001 11:08 AM To: Mazzullo, Ed Subject: Hewiett-Packard getting a letter this week? When ever it may be ready, please have someone Ed, we are eager to bring closure to this inkjet matter. Any chance of phone me at 393-5710 and I will send a messenger to pick it up. Thanks. <<>> LAW OFFicES LAWRENCE W, BIERLEIN JOHN M. CUTLER, JR DOUGLAS M. CANTER MCCARTHY, SWEENEY & HARKAWAY, P.C. SUITE 600 202) 393-5721 FACSIMIS STEVEN J. KAUSH ANDREW P. GOLOSTEIN 2175K STREET, N.W. HARVEY L. RETTER RICHARD D. LUEBERMAN WASHINGTON, D. C. 20037 MISH@MSHAC.COM E-Mar (202) 393-5710 Weesire WuUAM I. HARKAWAY OF COUNSEL HTTP//MNW.MSHAC.COM October 17,2000 DANIEL J. SWEENEY KAREN R. O'BREN To: Jim O'Steen Ed Mazzullo / From: Lary Bin Ten Re: Hewlett-Packard ink testing I appreciated the chance to talk to you about the Hewlett-Packard inkjet cartridges and our pending request for an approval. In order to provide you with more information about the ink itself, I have enclosed two items First is an MSDS for the most aggressive of the range of inks aflected, Zaphod Yellow. As you can see, the flash point is greater than 200°F The second enclosure is a rest report. As noted in the onginal application, the cartridges range in capacity from about 35 mi to 750 mi, with more than 90% being about 35 ml. Because the device contains the ink, and the device itself is extensively overpacked, the likelihood of any release is virtually non-existent. If there were a release, however, the amount released would be small. This is an ink and it is intended to dry rapidly. While it would dry faster on paper, nonetheless even a spill onto a metal surtace dries quickly. In order to assess the corrosive effects of a simulated spill, i.e., in which the steel coupon is wet with the ink but then the ink is allowed to dry, the company ran three tests. The test method is somewhat different from the draft I sent you last week. In the enclosed test report, three sample steel coupons were used. As described in for a week. The assumption is that the comosive effects on steel stop when the ink dries, and this longer test should confirm that assumption. I will call one of you tomorrow to see how this information might be used to support the requested "quantity and form" approval requested Thank you. <<>> • ..... Memorandum To: Tim Carey/SERM Jim Colby/ISO Packaging CC: Kathy Brewer/SERM From: Barbara Hanley/SERM Date: October 12, 2000 Re: Results and Summary of Zaphod Yellow Ink Dry Tim and the Observed Affects on the Corrosion Rate to SAE1020 Steel This memo is to inform the distribution of the results from a materials compatibility analysis completed today. The memo is structured by giving a background as to why the experiment was performod, the summary of the results, followed by the analysis procodure usod. Background and Analysis Goal discovered that the color (yellow, magenta and cyan) inks that are used in the No. 10 and No. 80 inkjet supplies During routine internal product testing of the inks and cartridge material used to manufacture inkjet supplies, it was exceeded the federal waste and transportation threshold for corrosivity to steel. The method used to determine corrosivity is found in EPA 530/SW-846 Method 1110, Corrosivity Towards Steel. heated to 55 degrees C and agitated. Although the inks exhibit the corrosivity characteristic under these test The method calls for the immersion of an SAE 1020 steel specimen in approximately 1000-ml of liquid, which is conditions, it was not known if they would corrode steel under more "real world" conditions. The analysis goal was to simulate an ink spill and determine if the ink would continue to exhibit the corrosion characteristic while drying or when dry. It is hoped that the data may answer this question. Summary of Results yellow showing the highest corrosion rate. For this reason, Zaphod yellow was chosen as the ink for this The ink used in the No. 10 and No. 80 inkjet supply were developed under the codename Zaphod, with Zaphod the Acid/Base fume hoods in the HP Corvallis Building 7 Analytical Lab as shown in Figures I and 2. For quality experiment. Three SAE1020 round steel coupons were used as the specimens. The experiment was set-up in one of control, a specimen was also exposed to DI Water, while another specimen was suspended in the hood, but not exposed to any liquid. Both the specimen and the liquid weights were measured on a Sartorius Model R200 year. The conditions of the analyses are listed at the end of this document. Balance, shown in Figure 3, capable of measuring out to five significant figures and calibrated in September of this the corrosion rate in millimeters per year (campy) of the three specimens used in the experiment. It can be seen from No significant differences were detocted between the specimens with regard to their corrosion rates. Table 1 shows the table that there were no significant differences detected between the spocimens with regard to their corrosion rate. <<>> hp ..r.. Table 1: Summary results from experiment ZAPHOD-BASED COLOR INK CORROSIVITY ANALYSIS Laphod Yellow and SAE 1020 steel coupons, tested ia B-7 Analytical Lab (10/10-11/00) Sample ID Surface (ст) Area Exposed To: Sample Volume Length of Exposure Time Dry Initial Final Wt (br) (br) (2 (mg) (mm/Yr). IAO181 AO182 25.66 25.63 DI Water Z-Y 1000 mol 0.0167 1000 mal 0.0167 24 24 23.99731 23.81670 23.99481 0.002.50 1.44 0.03 AO184 25.54 Air NA 0.0167 24 23.45772 23.457351 0.00037 2.50 0.05 0.37 0.01 Figure I: Experiment set-up - Figure 2: Experimental setup after exposure 993 <<>> anys Figure 3: Balance used to weigh specimens Analysis procedure Specimen preparation and cleaning: The specimens were ordered from Alabama Spocialty Metals, Lac. and arrived in sealed paper packets. Each specimen was stamped with a material code (C1020) and individual identification number (AOXXX). The sealed packets for the specimens used in this experiment were not opened until the day of the experiment and were always handled using nitrile gloves. Because the samples were brand new, a proclean step was not performed. Afer Microscope (SEM) lab for pre-exposure surface micrographs. measuring the outer diameter, inner hole diameter and thickness, the specimens were sent to the Scanning Electron Attough he painis seld with a Fight , opt, lor dad erecipeate five, he samples le of ach specimen was threaded with plastic fishing line. After exposure, each spocimen was immersed in a 1:10 non-chlorine cleanser/tap water mixture at ambient temperature and allowed to soak for S minutes. Then, the immersed specimens were placod on an electric stirrer for another five minutes. The specimens were removed from the immersion jars, rinsed with tap water and patted dry using a sterile Tea-Wipe. The specimens were weighed and sent back to the SEM lab, where post-exposure micrographs were taken. While at the SEM lab, the specimens were cleaned with high-pressure COr gas to remove ink residue. To reduce variability, the cleaning tochnique was applied to all three specimens. Liquid Preparation, Ser-up and Specimen Exposure: four neck Pyrex lid. Standard non-mercury filled thermometers were used to monitor liquid and air temperature. The ink used was Zaphod Yellow from the Building 7 Proto Lak Lab. Two 1000-ml Pyrex Keck flasks, fitted with a Che DI Water was obtained tbrough the house system, which has a resistivity specification set at 18 MOms. The lasks were fitted with condensers, although these were not used during this experiment. Also, only one ink-filler <<>> Enviroa MP Supplice ne specimen was suspended on the end of the lab rack as a control. The other two specimens were immersed it aphod yellow ink or DI water for one minute. These spocimens were suspended on the lab rack for 24 hours, wit After the dry-time measurement, the specimens were removed from the lab rack, cleaned, dried, and weighed as period dry time checks taken at one hour and 13 hours and 24 hours, as shown in Figures 4, S, and 6, respectively. shown in Figure 7. Figure 4: Dry time check after exposure. Figure 5: Dry time check after exposure. Elapsed dry time: 1 hour Elapsed dry time: 13 hours Figure 6: Dry time check after exposure. Elapsed dry time: 24 hours <<>> LIp à Figure 7: Specimens after various exposures A0182 - A0184 - AO181- Zaphod Yellow ink; 1 min exposure to Control spocimen; 1 min exposure to Air, 24-hours Deionized Water 24-hour dry time (18 MOhm); 24-hour dry time <<>> • DIJ00350 Material Safety Data Sheet DuPont Page 1 ZAPHOD YELLOW INK Revised 21 June 2000 PRODUCT AND COMPANY IDENTIFICATION Product Name: ZAPHOD YELLOW INK Product Code: Nos Assigned Company Identification MANUFACTURER/DISTRIBUTOR DuPont Ink Jet Inks and Specialty Colorants Wilmington, DE (USA) Barley Mill Plaza PHONE NUMBERS Product, Safety, Health and Transport Emergency Environmental Information Medical Emergency COMPOSITIONINFORMATION ON INGREDIENTS Components (% by weight) Material CAS Number Humectant Water 7732-18-5 55-80 Succinic Acid 5-10 2-Pyrrolidone Aliphatic Polyol 110-15.6 5-10 5-10 Inorganic Nitrate 616-45-5 5-10 Yellow Dyes <1 < Components (Remarks) withheld as a trade secret. "The specific identity for each component not identified by a CAS Registry Number is <<>> * * DIJO0350 DuPont Material Safety Data Sheel Pago 2 3. HAZARDS IDENTIFICATION Potential Health Effects THIS PRODUCT CAN BE USED SAFELY WHEN USED AS DIRECTED AND WHEN APPLICABLE SAFETY PRECAUTIONS ARE FOLLOWED. POTENTIAL HEALTH EFFECTS FROM PRODUCT inhalation of vapor. Potential routes of overexposure to this product are skin contact, eye contact an Ingestion is nor expected to be a significans route of exposure for this product under normal use conditions. There is no toxicity data avatable for this specific formulation. Any potential hazards are presumed to be due to exposure to the components. This material has been found to be corrosive to SAE Type 1020 sleel. No skin test data are avatable. ADDITIONAL HEALTH EFFECTS of exposure, information is provided for each hazardous component of the mixture to Since this mixture has not been tested as a whole to determine the hazards by all roules meet requrements of OSHA's Hazard Communication Standard (29 CFR 1910.1200). The effects noted occur from exposure to the pure component unless otherwise noted. INFORMATION FOR COMPONENTS HUMECTANT Skin Contact - Essentially non-imitating, Sightly foxic to animals by absorption. Eye Contact - Essentially nor-irritating. Medical Conditions Aggravated by Exposure - Significant exposure to this chemical may adversely affect people with chronic disease of the respiratory system, skin and/or eyes. SUCCINIC ACID rats showed no adverse effects. Tests in chick embryos demonstrated no mutagenic This material is a sight skin irritant and a strong eye irilant. Short term feeding studies ir activity. Symptoms of acute toxicity in rats are weakness and diarrhea. initially include: skin irrilation with discomfort or rash; or eye irritation with discomfort. Human health effects of overexposure by inhalation, ingestion, or skin or eye contact may fearing or blurring of vision. Data to evaluate the skin permeation hazard of this material are insufficient. <<>> DIJO0350 Dupont Material Safety Data Sheet Page 3 ALIPHATIC POLYOL by skin absorption. Harmful if inhaled or swatowed. May cause eye imlation May cause Not a skin or eye imtans in animals. Low toxicty in animals by ingestion and sight toxicity skin irritation. Exposure can cause gastrointestinal disturbances, nausea, headache and 2 PYRROLIDONE vomiting or diarrhea. 2-Pymrolidone may irritate skin, eyes, nose and throal Ingestion may cause nausea. INORGANIC NITRATE This material is an eye and upper respiratory tract irriant. Ingestion may lead to breath, bluish discoloration of the skin and mucous membranes, nausea and headache. methemoglobinemia and gastric tritation with symploms of weakness, shortnoss of Carcinogenicity Information by JARC. NTP, OSHA or ACGiH as a carcinogen. None of the components present in this material al concentrations equal to or greater than 0.1% are listed FIRST AID MEASURES First Aid INHALATION lf inhaled, remove to fresh air, If not breathing, give artificial respiration. If breathing is difficult, give oxygen. Call a physician. SKIN CONTACT Flush skin with water after contact. Wash contaminated clothing before reuse. EYE CONTACT In case of contact, immediately flush eyes with plenty of water for at leas! 15 minutes. Call a physician. INGESTION Ingestion is not an expected route of exposure during normal use of the product. if ingested, consult a physician. <<>> DIJO0350 Material Safety Data Sheet Dupont Page 4 5. FIRE FIGHTING MEASURES Flammable Properties Flash Point Method : Closed Cup :>200 °F (>93.3 °C) Approximate Flammable Limits in Air, % by Votume * Nol Avadable Autoignition Temperature : Not Avatable : Not Avatable Materialis a nonflammable water-based solution Hazardous combustion products (gases /vapors) produced in fire can inctude carbon monoxide, carbon dioxide and smoke. Extinguishing Media Use media appropriate for surrounding material. Fire Fighting Instructions This material is not flammable. Use normal firefighting procedures for the area. 6. ACCIDENTAL RELEASE MEASURES Safeguards (Personnel) NOTE: Review FIRE FIGHTING MEASURES and HANDLING (PERSONNEL) sections EQUIPMENT during clean-up. before proceeding with clean-up. Use appropriate PERSONAL PROTECTIVE Initial Containment Dike spil Spil Clean Up Soak up with absorbent material. HANDLING AND STORAGE Handling (Personnel) Avoid contact with eyes, skin, or clothing. <<>> * DIJ00350 Material Safety Data Sheet Dupont Page 5 EXPOSURE CONTROLS/PERSONAL PROTECTION Personal Prolective Equipment EYE/FACE PROTECTION Veas safety glasses. Wear coverall chemical splash goggles and face shield when th ossibdity exists for eye and face contact due to splashing or spraying of the materia RESPIRATORS Respirators are not needed for normal use. PROTECTIVE CLOTHING if there is potential for significant dermal contact weas appropriate impervious clothing and Exposure Guidetnes pplicable Exposure Limit PEL (OSHA) LUMECTANT TV (ACGIH) : None Established AEL * (DuPont) * None Estabished * None Estabished SUCCINIC ACID TLV (ACGIH) PEL (OSHA) : None Established AEL • (DuPont) : None Established : None Established PEL (OSHA) ALIPHATIC POLYOL TLV (ACGIH) i None Estabished AEL • (DuPont) : None Estabished 2-PYRROLIDONE PEL (OSHA) TLV (ACGIH) * None Established AEL • (DuPont) : None Estabished : 10 ppm, 35 mg/m', 8 & 12 Hr. TWA INORGANIC NITRATE PEL (OSHA) AEL • (DuPont) TLV (ACGIH) ¿ None Established : 10 mg/m*, 8 Hr. TWA * None Estabished YELLOW DYES PEL (OSHA) TLV (ACGIH) *None Established AEL • (DuPont) ¿ None Estabished : None Estabished <<>> D1J00350 Material Safety Data Sheet DuPont Page 6 •AEL is DuPont's Acceptable Exposure Limit. Where governmentally imposed take precedence. occupational exposure limies which are lower than the AEL are in effect, such limits shall 9. PHYSICAL AND CHEMICAL PROPERTIES Physical Data Color Form : Liquid Solubility in Water Odor : Yellow : Slight pH : Miscible Specific Gravity ·3.5-4.5 : 1.06 10. STABILITY AND REACTIVITY Chemical Stabitty Stable at normal temperatures and storage conditions. Incompatibility with Other Materials Corrosive to SAE Type 1020 steel Decomposition Decomposition does not oocus during normal use. Polymerization Polymerization will nol occur. 11. TOXICOLOGICAL INFORMATION Animal Data No data avalable for product. <<>> DIJO0350 Material Safety Data Sheet DuPont Page 7 12. ECOLOGICAL INFORMATION Ecoloxicological Information No data avatable for produce 13. DISPOSAL CONSIDERATIONS Waste Disposal Treatment, storage, transportation, and disposal must be in accordance with appticable Federal, State/Provincial, and Local regulations. 14. TRANSPORTATION INFORMATION (Not meant to be all inclusive) DOT (Department of Transportation): Proper Shipping Name : CORROSIVE LIQUID, ACIDIC, ORGANIC. N.O.S. Hazard Class (SUCCINIC ACID) Identification Number Packing Group : UN3265 15. REGULATORY INFORMATION (Not meant to be all inclusive - selected regulations represented) U.S, Regulations Federal Regulations TSCA Inventory Status - All components of this product are compliant with TSCA chemical inventory regulations. TSCA Section 12(b) Export Notification - This product can contain: None <<>> • DIS00350 Material Safety Data Sheel Dupont Page 8 State Regulations State Right-To-Know CANCER, BIRTH DEFECTS OR OTHER REPRODUCTIVE HARM (Caldomia WARNING - SUBSTANCES KNOWN TO THE STATE OF CALIFORNIA TO CAUSE Proposition 65) Ethytene Oxide (75-21-8) Formaldehyde (50-00-0) <0.5 ppm 1,4-Dioxane (123-91-1) <0.1 ppm Acetaldehyde (75-07-0) 0.1 ppm 0.1 ppm The above are trace impunties that can occur in the product. European Union Regulations inventory regulations. EU Inventory Status - All components of this product are compliant with EU chemical 16. OTHER INFORMATION HMIS Rating Flammabitty Health "1 Reactivity "1 * 0 herein and does not relate to use in combination with any other material or in any process. The data in this Material Safety Data Sheet relates only to the specific material designated MSDS Contact Information DuPont ink Jet Inks and Specialty Colorants Product Stewardship Coordinator Wimington, DE (U.S.A.) Barley Mitt Plaza 1-302-695-9682 (U.SA.) Revision History 2 February 2000 2 May 2000 New MSDS format Modifications to Sections 3 and 4 - Inhalation 21 June 2000 Section 15 - Calfornia Proposition 65 Sections 2, 3, 8, 10. 14, 15 - Corrosive to steel <<>> DIJ00350 Material Safety Data Sheet DuPont Page 9 Key ACGIH AEL American Conference of Governmental Industrial Hygienists ET Cmpos Compounds Acceptable Exposure Limit (DuPont) EU Eastern Time (U.S.A) HMIS European Union Hazardous Material Information System (National Paint and Coatings LEL or LFL LARC International Agency for Research on Cancer Association) M-F Lower Explosive Limit of Lower Flammable Limit OSHA NTP National Toxicology Program (U.S.A) Monday through Friday STEL PEL Occupational Safety and Heath Administration (U.S.A) Permissible Exposure Lmit TSCA TLV Threshold Limit Value Short Term Exposure Limit TWA Toxic Substances Control Act (U.S.A) UEL or UFL Time weighted Average WEEL Upper Explosive Limit or Upper Flammable Limit Workplace Environmental Exposure Level End of MSDS <<>> • LAW OFficEs LAWRENCE W. BIERLEN MCCARTHY, SWEENEY & HARKAWAY, P.C. JOHN M. CUTLER JR SUITE 600 202) 393-5721 FACSIMRA ANDREW P. GOLOSTEIN 2175 K STREET, N.W. HAAVEY L. REITER RICHARO D. LIEBERMAN WASHINGTON, D. C. 20037 MSH@MSMAC.COM E-MAT (202) 393-5710 Wessite Or COUNSEL MTT://WW.MSHOC.COM NUR HAKWAY January 5, 2001 DANIEL J SWEENEY Mr. James O'Steen Director, Office of Hazardous Materials Technology (DHM-20) Research & Special Programs Administration Washington, DC 20590 Department of Transportation cc: Mr. Edward Mazzullo, Standards (DHM-10) Mr. James Enoch Jones, Approvals (DHM-32) Re: Pending Hewlett-Packard approval application; inkjet printer cartridges Dear Mr. O'Steen: On September 1, 2000, I submitted an application on behalf of Hewlett-Packard artridges shipped by that company and its customers company for an approval under 49 CFR 173.136(b) covering a range of inkjet printe My request was prompted by preliminary test information indicating that some of the inks utilized in the company's printers fell within the definition of a steel-corrosive material in 49 CFR 173.137(c)(2), and therefore would require shipment of the cartridges in Class 8, Packing Group III. As you know, while we have been discussing this application, the company has continued to have corrosivity tests conducted on its inks under the standards in the U.S. and the international dangerous goods regulations. This has been made somewhat more difficult because of the commercial unavailability of the P3 and P235 steels cited in the regulations. Both title 49 CFR and the UN Orange Book, however, indicate that test steels of "a similar type" may be used to determine the classification. Enclosed are the most recent results using K02400 steel to test the company's Zaphod Yellow Ink. This ink was chosen because both company chemists and outside laboratories determined it would be the most aggressive of the inks offered in the cartridges. Along with these test results is a chart comparing the chemistry of K02400 steel to that of P3 and P235 steels. Based on this chart, we believe K02400 to be a "similar" steel to P3 and P235 as that term is used in the regulations. <<>> Based upon the 14-day test results utilizing this steel, we believe that the ink does not fall within the scope of the hazardous materials regulatory definitions for steel. corrosion. We chose this time period because we know it has been used before in the context of DOT corrosive materials classification, and because it appears to be a closer replicate to an annual corrosion rate as specified in the regulations than a shorter test period. As indicated in our original application, based upon actual testing, we know that the ink is not skin or aluminum-corrosive, and that it does not meet the definition of any other hazard class. If, upon your review of this data and test results, you agree with my conclusion that these inks do not fall not within the scope of the regulations, consider this a request to withdraw the pending approval application. Please contact me if you have any questions on this material. Thank you. For Hewlett-Packard Enclosures <<>> • Sent By: HEWLETT PACKARD; 01/03/2821 27:12 368-6361868 5417152237 CUNETA AVAVICA Jan- 3-01 6:19PM; Page 2/3 PAGE 82 A Combia Analytical Services ac in Enooyoo-Omnad company Januery 3, 2001 Service Roguest No: K2009326 Barbara Hanley Howiett Packard Company 1000 NE Circle Boulevard Corvallis, OR 97330 Dear Barbara: or your reterence, these analyses nave beca assigaed our service request numbes K 200932 closed are the roots of the rush samplo 3) submitted to our laboratory on December 04, 2001 All analyses were performed according to our leboratory's quality assurance programa. All results are interded to be considered in their entirety, and Columbia Analytical Services, Ina. (CAS) is not responsible for use of less then the complete report. Results apply only to tho seoples analyzed Please call if you have any questions. My extension is 3280. Respoctfully submitted, Colursbia Aralytical Services, Isc. Les Kennody Project Chemist LK/gep Pagel of _ 1317 South 13th Avenue • P.O.Box 479 • Kelso, Washingion 98626 • Telephone 360/ 577-7222 • Fax 3601636-1065 <<>> 2/3/1 5417152237; CAS XBLSO Jan-3-01 6:19PW; Page 3/3 4003 COLUMBIA ANALYTICAL SERVICES, INC Aretical Report Cheats * Project: Hewiet Packard Compery Sample Matrixs NA Serrico Roguest: K2009326 Misc Date Collected: 12/400 Dato Received: 12400 Corrastriry Toward Secel (typo KO2100) Prep Method: Analysis Method: ASTM G31-72 NONE TEst Nores: Units: moWYR Besis: NA Sample Nashe Leb Code MRL MDL Rector Dilation Date Istracted Anstyced Result Dale Barall Notes Zephod Yetoresak A 186r Zephod Yellow lak 3 45br K2009326-001 K2009326-003 K2009326-002 : Zaphod Yollow lak C 48hr Zapbod Yellow bak D 48 br Zephod Yellow Sax B 45tr K2009326-004 Zapbod Yellow lak 8 7 day K2009326-003 Zapbod Yollow Ink H 7 day Zapbod Yellow Lak Q7 day K2009326-006 K2009326-007 K2009326-008 K2009326-009 - 77737337777777 Zepbod Yellow Ink J 7 day Zephod Yellow Ink 17 day Zapaod Yellow Ink K 14 dey K2009326-010 Zepbod Yellow Ink L 1,4 day K2009326-011 Taphod Yellow Ink M 14 day 82009326-012 Zaphod Yellow Lak N 14 day K2009326-013 K2009326-014 - LA8267779 Approved By:_ is kenners -Date 1/3/01 00528727992.seOE 2001 Peso te <<>> Corrosion rate of K02400 When Exposed to Zaphod Yellow Ink (CAS) 42.00 39.00 36.00 33.00 32.91÷ 30.00 27.00 24.00 Corrosion rate (mmpy) 21.00 - Corr rate (mmpy) 18.00 15.00 12-86- 12.00 9.00 6.00 223 U.S. DOT Threshold 3.00 6.25 mm/lyr 0.00 2-day 7-day 14-day Time interval of exposure CAS, KO2400 average lOW Thigh Trange error+/- # of samples 2-day] 32.91 25.82 39.35 13.53 6.94 5 7-day! 12.86 11.2 15.02 3.82 1.91 5 14-dayl 5.89 5.71 6.22 0.51l 0.25 4 <<>> Steel Type Composition Steel Type [Carbon (%) Silicon (%) Chromium (%) Manganese (%) | Aluminum (%) | Molybdenum (%)| Copper (%) Nickel (%) - <0.1 0.1 - 0.4 0.4 - 0.75 0.2 - 0.6 1.0 - 1.5 P235 <0.17 <0.35) <0.3 0.4 - 1.2 <0.08 <0.3 20.3 K02400 0.241 0.13 - 0.55 0.25 0.65 - 1.4 0.08 0.35 0.25 - SAE 1020 0.18-0.241 0.3 - 0.61 * Sum of chromium, copper, molybdenum, and nickel is loss than 0.7% - Indicates elements are not added as an alloying agent but may be present in trace quantities Sourcos: ASTM DS-56G: Unified Number System, 8th Ed., January 1999 Intemational Standards Organization, Standard 9328-2, 1991 <<>> -. January, 2001 Mr. Lawrence W, Bierlein 2175 K Street, NW Washington, DC 20037 Dear Mr. Bierlein: On September 1, 2000, on behalf of Hewlett-Packard Company, you applied for an approval to ship certain inkjet cartridges as unregulated materials. This is in response to your subsequent letter of January 5, 2001, enclosing results of certain steel corrosion tests and a comparative chart on steel compositions. We have reviewed thai test data and chart, and conclude that the KO2400 steel rested is sufficiently "similar to" P3 and P235 steels, as that term is used in the Hazardous Materals Regulations (HIMR) and the UN Model Regulations on the Transport of Dangerous Goods, to be accepted for Class 8 classification purposes. We also conclude, based upon the 14-day test results you provided, that the ink in the Hewlett-Packard inkjet printer cartridges does not meet the definition of a corrosive material as set forth in the U.S. HMR in 49 CFR 173.136-137, and in international regulations based upon Chapter 2.8 of the UN Model Regulations on the Transport of Dangerous Goods. Accordingly, because the ink is not regulated as a hazardous material, the approval you originally requested is not necessary and, per your letter, we are returning the approval application to you. Sincerely, ## Provenance - Official: Yes - Source: - Source ID: `phmsa` - SHA-256: `0be09a7a6e9c569f76719bf8f683ad0e4902b59d2e811224d2cf959ecc030a6d` - Retrieved: 2026-08-20T00:59:31.977Z - Exported: 2026-08-23T00:04:49.701Z - Document slug: `phmsa-interpretation-01-0234` ### Source metadata ```json { "materialSubtype": "interpretation", "interpretationArea": "hazardous_materials", "representation": "full_text_from_official_pdf", "companies": [], "individuals": [ "Mr. Lawrence W. 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