# The Law Offices of Michael A. Capuzzi — Hazardous Materials Safety Interpretation **Citation:** 08-0294 **Type / status:** guidance / guidance **Agency:** Pipeline and Hazardous Materials Safety Administration **Effective:** Not stated **Published:** 2008-12-30 08-0294 response to The Law Offices of Michael A. Capuzzi concerning 173.154, 173.24. ## Document text <<>> U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Ave.. S.E Washington, DC 20590 DEC 3 0 308 Mr. Michael A. Capuzzi, Esq. The Law Offices of Michael A. Capuzzi 63 14 North Wyndwood Drive Crystal Lake, IL 600 14 Ref. No. 08-0294 Dear Mr. Capuzzi: This is in response to your letter dated December 1, 2008, requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 17 1 - 1 80). Specifical!~, you ask for confirmation of your understanding of the labeling requirements for limited quantities of corrosive materials. In your letter, you state a typical shipment consists of seven boxes, containing a total of 84, one-half pound jars of a material described as "Corrosive solid, n.0.s. (Zinc chloride, lithium chloride-anhydrous mixture), UN 1759, PG 11" and two boxes containing a total of 24, thirty- two ounce bottles of a material described as "Corrosive liquid, n.0.s. (Zinc chloride, Hydrochloric acid), UN 1760, PG 111." The nine boxes are shipped together on a shrink wrapped pallet. The HMR provide exceptions for limited quantities of Class 8 materials, depending on how they are packaged and transported. Section 173.154(b) authorizes Class 8 Packing Group I1 materials to be transported as a limited quantity when placed in inner packagings with a capacity of up to 1.0 L (0.3 gal) for liquids or 1.0 kg (2.2 pounds) for solids placed in a strong outer packaging. Class 8 materials meeting Packing Group 111 may be transported as a limited quantity when placed in inner packagings of a capacity of up to 5 L (1.3 gallons) for liquids or 5 kg (1 1 pounds) for solids placed in a strong outer packaging. The completed package must not exceed 30 kg (66 pounds). When complete, the package must conform to the general packaging requirements prescribed in $ 5 173.24 and 173.24a. When transported by aircraft, the Class 8 material must be authorized for transport on board passenger-carrying aircraft, and the package must conform to the general requirements for transportation by aircraft prescribed 5 173.27. Limited quantity packages are excepted from labeling, unless transported by aircraft, and placarding, as prescribed in Subparts E and F of Part 172. Packages containing limited quantities must be marked in accordance with Subpart D of Part 172 and the shipping paper must include the words "Limited Quantity" or "Ltd Qty" following the basic description. <<>> Based on the information you provided, the nine boxes placed onto a pallet and surrounded in shrink wrap would meet the definition of an overpack. Authorized packages containing hazardous materials may be offered in an overpack when they meet the requirements of tj 173.25. The overpack must be marked with the proper shipping name and identification number and labeled as applicable, unless the markings and labels representative of each hazardous material in the overpack are visible. I hope this satisfies your inquiry. If we can be of further assistance, please contact us. Sincerely, F0f Charles E. Betts Chief, Standards Development Office of Hazardous Materials Standards <<>> m l ( H A E 1 ( A P U Z Z I T R A D E L A W December 1,2008 Office of the Chief Counsel, Pipeline and Hazardous Materials Safety Administration Department of Transportation Attn: PHC- 1 0 East Building 1200 New Jersey Avenue, SE Washington, DC 20590-000 1 Re: Interpretive Ruling Request - Labeling of Limited Quantities Dear Sir or Madam: On behalf of Tacna International Corp. (hereinafter "Tacna") and in accordance Section 105.20 of the Pipeline and Hazardous Materials Safety Administration (hereinafter "PHMSA") regulations (49 CFR $105.20), we respectfblly present the following request for an interpretive ruling. Given that on-going shipments are impacted by the guidance offered by the interpretative ruling, we respectfully request expedited processing. I. Overview Tacna is the importer of various goods produced in Mexico. Among the items imported are various types of solders, fluxes, and other welding preparations. The Law Offices of Michael A. Capuzzi 6314 North Wyndwood Drive Crystal Lake, IL 60014 Tel: 815-479-5260 Fax: 815-479-1904 <<>> f f l l ( H A E 1 ( A P U Z Z I T R A D E L A W A typical shipment consists of several packagings, e.g. jars, bottles, etc, packed in a cardboard box, with several cardboard boxes shrink-wrapped on a pallet. For the purposes of this ruling request, we will use the following information as being representative of a typical shipment: Seven boxes containing a total of 84 one-half pound jars of Harris Products Group Al- Braze 1070 Flux, Part JW-1070112; and Two boxes containing a total of 24 thirty-two ounce bottles of Harris Products Group Stay-Clean Liquid Flux, Part JW-SCLF32. The nine boxes are shipped together on a pallet with plastic shrink-wrap surrounding the boxes. The questions involving this type of shipment are: 1) What labeling, if any, of the packagings and shipping boxes is required under the PHMSA regulations? 2) What labeling, if any, is required for the shrink-wrapped pallet? 3) If the pallet is labeled, what labeling requirements, if any, are then placed on the packages and overpack shipping boxes as a result of said pallet labeling? Our position regarding these questions follows. The Law Offices of Michael A. Capuzzi 6314 North Wyndwood Drive Crystal Lake, IL 60014 Tel: 815-479-5260 Fax: 815-479-1904 <<>> T R A D E L A W 11. Discussion - Labeling of the Packaginp and Shipping Boxes Harris Products Group Al-Braze 1070 Flux, Part JW-1070112 The Harris Products Group Al-Braze 1070 flux (hereinafter "Al-Braze flux") is a powdered brazing flux. The imported Al-Braze flux is packaged in one-half pound jars for retail sale. Attached for your ready reference is a catalog page showing a representative sample jar of Al-Braze flux. As outlined in Section One of the Material Safety Data Sheet (hereinafter "MSDS"), the chemical name of the Al-Braze flux is "Alkali Metal Halide Powder." Section Fourteen of the MSDS lists the proper shipping name as "Corrosive Solid, n.0.s." This section of the MSDS states that the Al-Braze flux has a hazard class number and description of "8 (Corrosive)," the UN Identification Number of "UN 1759," and the packing group as "11." Section Fourteen of the MSDS also states the Department of Transportation (hereinafter "DOT") label required for the Al-Braze flux is "Corrosive." A copy of the MSDS for the Al-Braze flux is included for your ready reference. Section 172.400(a) of the DOT regulations (49 CFR 9 172.400(a)) states in pertinent part: Except as specified in $1 72.400a, each person who oflers for transportation or transports a hazardous material in any of the following packages ..., shall label the package ... with labels spec$ed for the material in the $1 72.101 table and in this subpart: (I) A non-bulk package; *** (5) An overpack ... which contains apackage for which labels are required ...; For products having a hazard class of "8," the label required by Section 174.400(b) is "Corrosive." The Law Off~ces of Michael A. Capuzzi 6314 North Wyndwood Drive Crystal Lake, IL 60014 Tel: 815-479-5260 Fax: 815-479-1904 <<>> m l ( H A E 1 ( A P U Z Z I T R A D E L A W Consideration of the Individual Jars of Al-Braze Flux as Non-Bulk Packaging Requiring Labeling under 49 CFR §172.4OO(a)(l) Section 17 1.8 of the DOT regulations (49 CFR 5 171.8) defines "non-bulk packaging" as: . . . (P)ackaging which has: (1) A maximum capacity of 450 L (1 19 gallons) or Iess as a receptacle for a liquid; (2) A maximum net mass of 400 kg (882 pounds) or Iess and a maximum capacity of 450 L (1 19 gallons) or Iess as a receptacle for a solid; or (3) A water capacity of 454 kg (1 000pounds) or Iess as a receptacle for a gas ... Section 17 1.8 of the DOT regulations further defines "packaging" as: ...(A ) receptacle and any other components or materials necessary for the receptacle to perform its containment function in conformance with the minimum packaging requirements ... "Receptacle" is defined by Section 171.8 as "...a containment vessel for receiving and holding materials. " The retail jar for the Al-Braze flux satisfies the definition of "packaging" in that the jar serves as the containment receptacle for the one-half pound quantity of corrosive flux. Given that each of the one-half pound Al-Braze flux packaging falls under the maximum limits set-forth for the definition of non-bulk packaging, the subject goods would also satisfy the definition of "non- bulk packaging" and would initially appear to be subject to the labeling requirements of 49 CFR 5 172.400(a). The Law Off~ces of Michael A. Capuzzi 6314 North Wyndwood Drive Crystal Lake, IL 60014 Tel: 815-479-5260 Fax: 815-479-1904 <<>> T R A D E L A W Consideration of the Twelve-Jar Box of Al-Braze Flux as an Overpack Requiring Labeling Under 49 CFR $172.400(a)(5) Section 172.8 of the DOT regulations defines "overpack" as: ...(A )n enclosure that is used ... to provide protection or convenience in handling of a package or to consolidate two or more packages ... Examples of overpacks are one or more packages ...p laced in aprotective outer packaging such as a box or crate. Section 171.8 of the DOT regulations defines "package" as " ... packagingplus its contents." As we have already established supra that the jar for the Al-Braze flux satisfies the definition of "packaging," the jar containing the Al-Braze flux satisfies the definition of "package." Section 172.8 of the DOT regulations defines "Outer packaging" as: ... (T)he outermost enclosure of a composite or combination packaging together with any absorbent materials, cushioning and any other components necessary to contain and protect inner receptacles or inner packagings. Section 171.8 of the DOT regulations defines "combination packagings" as: ... (A) combination of packaging, for transport purposes, consisting of one or more inner packagings secured in a non-bulk outer packaging. "Inner packaging" is defined by Section 171.8 of the DOT regulations as " ... apackaging for which an outer packaging is required for transport. .." The shipping box clearly satisfies the definition of an "overpack" given that the box provides protection of, and "convenience in handling," the twelve individuals packaging jars of Al-Braze flux contained therein. To summarize, the jars for the Al-Braze flux satisfy the definition of inner packaging, the jar containing the Al-Braze flux satisfies the definition of a package, and the twelve-jar box of Al-Braze flux satisfies the definition as an outer packaging. Therefore, the box containing the subject goods would also satisfy The Law Offices of Michael A. Capuzzi 6314 North Wyndwood Drive Crystal Lake, IL 60014 Tel: 815-479-5260 Fax: 815-479-1904 <<>> T R A D E L A W the definition of an "overpack" and would initially appear to be subject to the labeling requirements of 49 CFR 5 172.400(a). Applying the Labeling Exception of 49 CFR §172.400a(b) to the Individual Jars of Al- Braze Flux as Non-Bulk Packaging Section 172.400a(b) of the DOT regulations (49 CFR 5 172.400a(b)) specifies that: Certain exceptions to labeling requirements are provided for small quantities and limited quantities in applicable sections in part 173 of this subchapter. Section 173 of the DOT regulations (49 CFR 5 173) provides for the general requirements for shipments and packagings of hazardous materials; Subpart D to Section 173 provides for various exceptions related to hazardous materials other than Class 1 and Class 7. Section 173.154(a) of the DOT regulations (49 CFR §173.154(a)) allows for Class 8 hazardous materials exceptions "...only if this section is referenced for the speciJic hazardous material in the $1 72.101 table ..." The Table of Hazardous Materials and Special Provisions contained in Section 172.101 of the DOT regulations (49 CFR 5 172.101) provides for, among other things, " ... requirements. ..pertaining to labeling ... " Column 8A of the table, as provided for by Section 172.10 1 (i)(l) of the DOT regulations, ". .. contains exceptions @om some of the requirements of this subchapter ..." Whereas the MSDS has established that the Al-Braze flux has a proper shipping name of "Corrosive Solids, n.0.s." with an UN identification number of "UN 1759," we must review the following section of the table found in Section 172.101 of the DOT regulations: The Law Offices of Michael A. Capuzzi 6314 North Wyndwood Drive Crystal Lake, IL 60014 Tel: 815-479-5260 Fax: 815-479-1904 <<>> l l l l ( H A E 1 ( A P U Z Z I T R A D E L A W Sfl- bds (11 G Hxmdmis materials d e m i p k m s a d proper shipping names Hz& dars as 0i- -an (2) C m o e ~ e solid% nas. .............. ... ..... .... .............................. (3) d ........... , ........... _ ........... -. ...... - - ...... ._ _. ... I .................... I Iden4iSw- lion Num- be^ 4 UNii5D PG (5) (6) I S ........ 10 e ........ (80 (9) (10) - Vessel nnav- Packapg Quaniily l i r r i t i a ~ - Spe%\!mm- ($173. "1 (see 89173.27 and 113.r5) age (8 Bi2.ttP) bulk 17) (an1 (SC) (*A) ( m ) (IDA) (103) IW. IP1. TB. None .... TP33 ~ T ~ . I B B . I P ~ . 1% ...... OP4. T3. TP33 21 1 ...... 242 ...... 1 ke 25 kg B ............ 212 ...... 240 ...... i 5 k ~ sorg A ......... .- 1 111 I 8 1 123, - IBB. -. IP3. .. I i54 I 213 I 240 I 25 kg , 100 kg I A I ........ ...... ...... ...... For goods under Packing Group I1 (as is the Al-Braze flux), the table of Section 172.101 identifies "154" under Column 8A. Given this notation, Section 172.101 of the DOT regulations authorizes the packaging exceptions of 49 CFR 5 173.154 for the subject product. Section 173.154@) of the DOT regulations (49 CFR 5 173.154(b)) outlines the exceptions permitted for limited quantities of Class 8 corrosive materials, specifically and in pertinent part: Limited quantities of corrosive materials (Class 8) in Packing Group 11 and 111 are excepted @om labeling requirements ... and the speciJication packaging requirements of this subchapter when packaged in combination packagings according to this . paragraph.. As the Al-Braze flux is Packing Group 11, the corresponding exceptions are found in Section 173.1 54@)(1) of the DOT regulations (49 CFR 5 173.154(b)(l)), which states in pertinent part: For corrosive materials in Packing Group II, inner packagings not over 1.0 L (0.3 gallon) net capacity each for liquids or not over 1.0 kg (2.2pounds) net capacity each for solids.. . Given that the one-half pound packagings of the Al-Braze flux are clearly under the 2.2 pound limit outlined in Section 173.154@)(1), the imported jars of Al-Braze flux are exempt from the hazardous materials labeling requirements of Section 172 of the Department of Transportation regulations. The Law Offices of Michael A. Capuzzi 6314 North Wyndwood Drive Crystal Lake, IL 60014 Tel: 815-479-5260 Fax: 815-479-1904 <<>> T R A D E L A W Applying the Labeling Exception of 49 CFR €j172.400a(b) to the Twelve-Jar Box of Al- Braze Flux as an Overpack As has already been outlined, Section 172.400(a)(5) of the DOT regulations requires the appropriate hazardous materials labeling for "(a)n overpack ... which contains a package for which labels are required.. . " (Emphasis added). It has been established that the individual jars of Al-Braze flux satisfies the definition of a "package" and that the box containing the twelve jars satisfies the definition of an "overpack." The critical regulatory labeling requirement of Section 174.400(a)(5) is that the overpack must contain packages "for which labels are required" in order for the overpack itself to be required to be labeled. As the individual packages of Al-Braze flux are excepted from the labeling requirements of Section 174.400 by Section 173.154(b) of the DOT regulations, the overpack does not contain packages "for which labels are required." Therefore, the twelve-jar boxes of Al-Braze flux are exempt from the hazardous materials labeling requirements of Section 172 of the Department of Transportation regulations. Harris Products Group Stay-Clean Liquid Flux, Part JW-SCLF32 The Harris Products Group Stay-Clean flux (hereinafter "Stay-Clean flux") is a liquid brazing flux. The imported Stay-Clean flux is packaged in thirty-two ounce bottles for retail sale. Attached for your ready reference is a catalog page showing a representative sample bottle of the Stay-Clean flux. As outlined in Section One of the MSDS the chemical name of the Stay-Clean flux is "Zinc Chloride/Arnmonium Chloride Solution." Section Fourteen of the MSDS lists the proper shipping name as "Corrosive Liquid, n.0.s." This section of the MSDS states that the Stay-Clean flux has a hazard class number and description of "8 (Corrosive)," the UN Identification Number of "LIN 1760," and the packing group as "111." The Law Offices of Michael A. Capuzzi 6314 North Wyndwood Drive Crystal Lake, IL 60014 Tel: 815-479-5260 Fax: 815-479-1904 <<>> T R A D E L A W Section Fourteen of the MSDS also states the Department of Transportation (hereinafter "DOT") label required for the Stay-Clean flux is "Corrosive." A copy of the MSDS for the Stay-Clean flux is included for your ready reference. Section 172.400(a) of the DOT regulations (49 CFR $172.400(a)) states in pertinent part: Except as speciJied in $1 72.400a, each person who oflers for transportation or transports a hazardous material in any of the following packages ..., shall label the package ... with labels speciJied for the material in the $1 72.1 01 table and in this subpart: (I) A non-bulk package; *** (5) An overpack ... which contains apackage for which labels are required ...; For products having a hazard class of "8," the label required by Section 174.400(b) is "Corrosive." Consideration of the Individual Bottles of Stay-Clean Flux as Non-Bulk Packaping Requiring Labeling under 49 CFR $172,40O(a)(l) Section 17 1.8 of the DOT regulations (49 CFR § 17 1.8) defines "non-bulk packaging" as: .. . (P)ackaging which has: (I) A maximum capacity of 450 L (1 19 gallons) or less as a receptacle for a liquid; (2) A maximum net mass of 400 kg (882 pounds) or less and a maximum capacity of 450 L (1 19 gallons) or less as a receptacle for a solid; or (3) A water capacity of 454 kg (1 000pounds) or less as a receptacle for a gas ... The Law Offices of Michael A. Capuzzi 6314 North Wyndwood Drive Crystal Lake, IL 60014 Tel: 815-479-5260 Fax: 815-479-1904 <<>> T R A D E L A W Section 17 1.8 of the DOT regulations further defines "packaging" as: ...(A ) receptacle and any other components or materials necessary for the receptacle to perform its containment function in conformance with the minimum packaging requirements .. . "Receptacle" is defined by Section 171.8 as "...a containment vessel for receiving and holding materials." The retail bottle for the Stay-Clean flux satisfies the definition of "packaging" in that the bottle serves as the containment receptacle for the thirty-two ounce quantity of liquid corrosive flux. Given that each of the thirty-two ounce packaging falls under the maximum limits set-forth for the definition of non-bulk packaging, the subject goods would also satisfy the definition of "non-bulk packaging" and would initially appear to be subject to the labeling requirements of 49 CFR $172.400(a). Consideration of the Twelve-Bottle Box of Stay-Clean Flux as an Overpack Requiring Labeling Under 49 CFR $172.400(a)(5) Section 172.8 of the DOT regulations defines "overpack" as: ...(A) n enclosure that is used ... to provide protection or convenience in handling of a package or to consolidate two or more packages ... Examples of overpacks are one or more packages.. .placed in a protective outer packaging such as a box or crate. Section 171.8 of the DOT regulations defines "package" as "... packagingplus its contents." As we have already established supra that the bottle for the Stay-Clean flux satisfies the definition of bbpackaging," the bottle containing the Stay-Clean flux satisfies the definition of "package." The Law Offices of Michael A. Capuzzi 6314 North Wyndwood Drive Crystal Lake, IL 60014 Tel: 815-479-5260 Fax: 815-479-1904 <<>> T R A D E L A W Section 172.8 of the DOT regulations defines "Outer packaging" as: ... (T)he outermost enclosure of a composite or combination packaging together with any absorbent materials, cushioning and any other components necessary to contain and protect inner receptacles or inner packagings. Section 171.8 of the DOT regulations defines "combination packagings" as: ... (A) combination of packaging, for transport purposes, consisting of one or more inner packagings secured in a non-bulk outer packaging. "Inner packaging" is defined by Section 171.8 of the DOT regulations as " ... a packaging for which an outer packaging is required for transport.. ." The shipping box clearly satisfies the definition of an "overpack" given that the box provides protection of, and "convenience in handling," the twelve individuals packaging bottles of Stay-Clean flux contained therein. To summarize, the bottles for the Stay-Clean flux satisfl the definition of inner packaging, the bottle containing the Stay-Clean flux satisfies the definition of a package, and the twelve-bottle box of Stay- Clean flux satisfies the definition as an outer packaging. Therefore, the box containing the subject goods would also satisfl the definition of an "overpack" and would initially appear to be subject to the labeling requirements of 49 CFR 8 172.400(a). Applying the Labeling Exception of 49 CFR §172.400a(b) to the Individual Bottles of Stay- Clean Flux as Non-Bulk Packaging Section 172.400aP) of the DOT regulations (49 CFR tj 172.400ae)) specifies that: Certain exceptions to labeling requirements are provided for small quantities and limited quantities in applicable sections in part 173 of this subchapter. The Law Offices of Michael A. Capuzzi 6314 North Wyndwood Drive Crystal Lake, IL 60014 Tel: 815-479-5260 Fax: 815-479-1904 <<>> T R A D E L A W Section 173 of the DOT regulations (49 CFR § 173) provides for the general requirements for shipments and packagings of hazardous materials; Subpart D to Section 173 provides for various exceptions related to hazardous materials other than Class 1 and Class 7. Section 173.154(a) of the DOT regulations (49 CFR $173.1 54(a)) allows for Class 8 hazardous materials exceptions "...only if this section is referenced for the specific hazardous material in the $1 72.101 table ... " The Table of Hazardous Materials and Special Provisions contained in Section 172.101 of the DOT regulations (49 CFR § 172.10 1) provides for, among other things, " ... requirements.. .pertaining to labeling. .. " Column 8A of the table, as provided for by Section 172.101(i)(l) of the DOT regulations, "...contains exceptions from some of the requirements of this subchapter ..." Whereas the MSDS has established that the Stay-Clean flux has a proper shipping name of "Corrosive Liquid, n.0.s." with an UN identification number of "UN 1760," we must review the following section of the table found in Section 172.101 of the DOT regulations: For goods under Packing Group I11 (as is the Stay-Clean flux), the table of Section 172.101 identifies "1 54" under Column 8A. Given this notation, Section 172.101 of the DOT regulations authorizes the packaging exceptions of 49 CFR § 1 73.1 54 for the subject product. The Law Offices of Michael A. Capuzzi 6314 North Wyndwood Drive Crystal Lake, IL 60014 Tel: 815-479-5260 Fax: 815-479-1904 <<>> m l ( H A E 1 ( A P U Z Z I T R A D E L A W Section 173.154(b) of the DOT regulations (49 CFR $173.154(b)) outlines the exceptions permitted for limited quantities of Class 8 corrosive materials, specifically and in pertinent part: Limited quantities of corrosive materials (Class 8) in Packing Group 11 and 111 are excepted @om labeling requirements ... and the speciJication packaging requirements of this subchapter when packaged in combination packagings according to this paragraph.. . As the Stay-Clean flux is Packing Group 111, the corresponding exceptions are found in Section 173.1 54(b)(2) of the DOT regulations (49 CFR $173.1 54(b)(2)), which states in pertinent part: For corrosive materials in Packing Group III, inner packagings not over 5.0 L (1.3 gallon) net capacity each for liquids or not over 5.0 kg (1 1 pounds) net capacity each for solids. .. Given that the thirty-two ounce packagings of the Stay-Clean flux are clearly under the 1.3 gallon limit outlined in Section 173.154(b)(2), the imported bottles of Stay-Clean flux are exempt from the hazardous materials labeling requirements of Section 172 of the Department of Transportation regulations. Applying the Labeling Exception of 49 CFR $172.400a(b) to the Twelve-Bottle BOX of Stay- Clean Flux as an Overpack As has already been outlined, Section 172.400(a)(5) of the DOT regulations requires the appropriate hazardous materials labeling for "(a)n overpack ... which contains a package for which labels are required.. . " (Emphasis added). It has been established that the individual bottles of Stay-Clean flux satisfies the definition of a "package" and that the box containing the twelve bottles satisfies the definition of an "overpack." The critical regulatory labeling requirement of Section 174.400(a)(5) is that the overpack must contain packages "for which labels are required" in order for the overpack itself to be required to be labeled. The Law Offices of Michael A. Capuzzi 6314 North Wyndwood Drive Crystal Lake, IL 60014 Tel: 815-479-5260 Fax: 815-479-1904 <<>> T R A D E L A W As the individual packages of Stay-Clean flux are excepted from the labeling requirements of Section 174.400 by Section 173.154@) of the DOT regulations, the overpack does not contain packages "for which labels are required." Therefore, the twelve-bottle boxes of Stay-Clean flux are exempt from the hazardous materials labeling requirements of Section 172 of the Department of Transportation regulations. 111. Discussion - Labeling of the Shrink-wrapped Pallet The next question involves the labeling of the shrink-wrapped pallet which contains several shipping boxes of limited quantities of goods, such as those described in Section I1 supra. Section 172.400(a) of the DOT regulations (49 CFR $172.400(a)) states in pertinent part: Except as speczjied in $1 72.400a, each person who offers for transportation or transports a hazardous material in any of the following packages ..., shall label the package ... with labels speczjied for the material in the $1 72.101 table and in this subpart: *** (5) An overpack ... which contains apackage for which labels are required ...; Section 172.8 of the DOT regulations defines "overpack" as: ...(A )n enclosure that is used ... to provide protection or convenience in handling of a package or to consolidate two or more packages ... Examples of overpacks are one or more packages ...p laced in aprotective outer packaging such as a box or crate. Section 17 1.8 of the DOT regulations defines "package" as " ... packaging plus its contents. " The Law Offices of Michael A. Capuzzi 6314 North Wyndwood Drive Crystal Lake, IL 60014 Tel: 815-479-5260 Fax: 815-479-1904 <<>> I l l l ( H A E 1 ( A P U Z Z I T R A D E L A W As we have already established supra that the jar for the Al-Braze flux and the bottle for the Stay-Clean flux satisfy the definition of "packaging," the corresponding jar and bottle containing the products satisfy the definition of "package." Section 172.8 of the DOT regulations defines "Outer packaging" as: ... (T)he outermost enclosure of a composite or combination packaging together with any absorbent materials, cushioning and any other components necessary to contain and protect inner receptacles or inner packagings. Section 171.8 of the DOT regulations defines "combination packagings" as: ... (A) combination of packaging, for transport purposes, consisting of one or more inner packagings secured in a non-bulk outer packaging. "Inner packaging" is defined by Section 17 1.8 of the DOT regulations as "...a packaging for which an outer packaging is required for transport ..." The shrink-wrapped pallet clearly satisfies the definition of an "overpack" given that the shrink-wrap and the pallet provides protection of, and "convenience in handling," the shipping boxes containing the individual packaging jars of Al-Braze flux and the individual packaging bottles of Stay-Clean flux contained therein. As has already been outlined, Section 172.400(a)(5) of the DOT regulations requires the appropriate hazardous materials labeling for "(a)n overpack ... which contains a package for which labels are required.. . " (Emphasis added). It has been established that the individual jars of Al-Braze flux and the individual bottles of Stay-Clean flux satisfies the definition of a "package," the box containing the packages satisfies the definition of an "overpack," and the shrink-wrapped pallet containing the shipping boxes also satisfies the definition of an "overpack." The critical regulatory labeling requirement of Section 174.400(a)(5) is that the overpack must contain packages "for which labels are required" in order for the overpack itself to be required to be labeled. The Law Oflices of Michael A. Capuzzi 6314 North Wyndwood Drive Crystal Lake, IL 60014 Tel: 815-479-5260 Fax: 815-479-1904 <<>> ( A P U Z Z I T R A D E L A W As the individual packages of Al-Braze flux and Stay-Clean flux are excepted from the labeling requirements of Section 174.400 by Section 173.154(b) of the DOT regulations, the overpack, i.e. the shrink-wrapped pallet, does not contain packages "for which labels are required." Therefore, the shrink-wrapped pallet containing the twelve-jar boxes of Al-Braze flux and the twelve- bottle boxes of Stay-Clean flux are exempt from the hazardous materials labeling requirements of Section 172 of the Department of Transportation regulations. IV. Discussion - Labeling of Boxes if Pallet is Labeled The final question involves what, if any, labeling is required on the packagings and overpack shipping boxes if the shrink-wrapped pallet overpack does contain labeling, e.g. "Corrosive" label. Because the goods originate in Mexico, the packagings, packages, and overpacks, including the shrink- wrapped pallet, must conform to the hazardous materials labeling requirements for Mexico; these labeling requirements may be different than that of the PHMSA. For example, the shrink-wrapped pallet may be required contain the appropriate "Corrosive" labeling for purposes of transportation in Mexico even though this labeling is not required by the PHMSA regulations. ' Section 5.1.2.1 of the "United Nations Recommendations on the Transportation of Dangerous Goods" states, in pertinent part: An overpack shall be ... labeled, as required for packages by Chapter 5.2, for each item of dangerous goods contained in the overpack unless marking and labeling representative of all dangerous goods in the overpack are visible. ' 49 CFR §172.401(a) states that a package may not bear a label required by the PHMSA regulations unless: 1) The package contains a material that is a hazardous material; and 2) The label represents a hazard of the hazardous material in the package. As was established in Section 11, the subject Al-Braze flux and Stay-Clean flux are "hazardous materials." As such, any labeling that may be placed on the packages or overpacks, including the shrink-wrapped pallet, said labeling being excepted by regulation, would not be in violation of 49 CFR §172.40l(a). The Law Offices of Michael A. Capuzzi 6314 North Wyndwood Drive Crystal Lake, IL 60014 Tel: 815-479-5260 Fax: 815-479-1904 <<>> f f l l ( H A E 1 ( A P U Z Z I T R A D E L A W The controlling requirements for the labeling of hazardous materials in the United States are found in the PHMSA regulations and not the UN Recommendations. As the subject packages and overpacks, including the shrink-wrapped pallet, are exempt from labeling under the PHMSA regulations, there is no labeling requirement placed on the packages or shipping box overpacks if the overpack pallet is labeled in accordance with the UN Recommendations. To summarize, if the shrink-wrapped overpack is labeled in accordance with the UN Requirements, the packaging and shipping boxes of the limited quantities of the subject goods are still exempt from labeling by regulation for the reasons reviewed supra. 111. Conclusion Based upon our understanding of the PHMSA requirements and a plain reading of the corresponding regulations, our position for each point is as follows: 1) What labeling, if any, of the packagings and shipping boxes is required under the PHMSA regulations? For reasons reviewed supra, the jars of Al-Braze powdered flux and bottles of Stay-Clean liquid flux are exempt from the labeling requirements of Section 172 of the Department of Transportation regulations. For reasons reviewed supra, the overpack boxes of the Al-Braze powdered flux and the overpack boxes of the Stay-Clean liquid flux are exempt from the labeling requirements of Section 172 of the Department of Transportation regulations. 2) What labeling, if any, is required for the shrink-wrapped pallet? For reasons reviewed supra, the overpack shrink-wrapped pallet containing the boxes of the Al-Braze powdered flux and the overpack boxes of the Stay-Clean liquid flux is exempt from the labeling requirements of Section 172 of the Department of Transportation regulations. The Law Offices of Michael A. Capuzzi 6314 North Wyndwood Drive Crystal Lake, IL 60014 Tel: 815-479-5260 Fax: 815-479-1904 <<>> f f l l ( H A E 1 ( A P U Z Z I T R A D E L A W 3) If the pallet is labeled, what labeling requirements, if any, are then placed on the packages and overpack shipping boxes as a result of said pallet labeling? For reasons reviewed supra, the jars of Al-Braze powdered flux and bottles of Stay-Clean liquid flux and the overpack boxes containing the same remain exempt from the labeling requirements of the Department of Transportation regulations even when the overpack shrink-wrapped pallet is labeled, for example, in accordance with the UN Recommendations. Please contact us should you have any questions or require any additional information. Thank you for your cooperation and assistance with the expedited response to this request. .Very sincerely, Hg%/.: Michael A. Capuzzi, sq. Counsel for Tacna International Attachments The Law Oflices of Michael A. Capuzzi 6314 North Wyndwood Drive Crystal Lake, IL 60014 Tel: 815-479-5260 Fax: 815-479-1904 <<>> AL-BRAZE 1070 A superior brazing alloy for the joining of aluminum to aluminum. Al-Braze is free-flowing with unequaled capillary attraction, ductility and penetration. Not recommended for brazing Aluminum directly to non-Aluminum alloys as the joint may be brittle. Procedre: . . Clean the braze area Remove all plating or anodized finish Heat the wire and dip into dry flux for extra coverage Mix powdered flux with water to form a paste Use a reducing flame Keep torch in constant motion Melt the alloy with the heat from the work piece not with the torch Features: Tensile strength - Up to 35,000 PSI Solidus - 1070°F 1577% Liquidus - 1080°F 1 58Z°C Excellent corrosion resistance Specific gravity - 2.66 USA WE lll At-Braze 1070 88% At 1070a F 1080' F Superior bming alloy for joining Aluminum 12% Si 5~ c 582' c aluminum to aluminum. Excellent Brazing Kit capillarl( atbarn. 1070K ALERAZE 1070 KIT aluminum alloy with non-corrosive flux inside the wire; no external flux is required with this praduct. Designed forth , air conditioners, aluminum alloy condensers and other applications. Very good fluidity with good capillary attractio ecessary. Better than tin-zinc and aluminum silicon alloys for aluminum coil repair. Melts at 824°F 1 440% aluminum torch alloy which is able to produce either th ded for brazing aluminum directly to non-aluminum alloys. CORAL is a tubular aluminum calibrated, assuring versatile control. ead forming characteristics. Aluminum to aluminum: Not the flux to the filler material is precisely be applied out-of-position with absolute Clean the braze area Remove all plating or anodized finish Leave agap of 1/16" to 118" Bevel 60" to 70" for butt joints or it is not necessary to melt the base Use a carburizing flame Solidus - 1 0 5 5 ~ ~ I 5 a 0 c Liquidus - 11 55°F I 623OC Goud color match (will Gwd corrosion resistance Can be applied out-of-position residue with warm water the md alter use to seal in flux The H a r r i s Products Group 1.800.733.4043 w w w . h a r r i s p r o d u c t s g r o u p . c o m <<>> MATERIAL SAFETY DATA SHEET Pmpmd to U.S. OSHA, CMA, ANSI and Candan WHMlS Standards .This Material Safely Data Sheet is offered pursuant to OSHA's Ha& Communication Standard (29 CFR 1910.1200). Other government regulations must be reviewed for applicability to Mese products. WARNING: PRODUCT COMPONENTS PRESENT HEALTH AND SAFETY HAZARDS. READ AND UNDERSTAND THIS MATERIAL SAFETY DATA SHEET (M.S.DS.). ALSO, FOLLOW YOUR EMPLOYER'S SAFETY PRACTICES. This product m y contain Chromium andlor Nickel which am llsted by OSH4 NTP, or IARC as being a carcinogen or potential carcinogen. Use of thls product may expose you or othen to fumes and gases at Iewls exceeding those establkhed by the American Conference of Governmental Industrial HygbnW (ACGIH) or the Occupational Safety and Health Adminkation (OSHA3 The information contained herein relates only to the specific produd If the pmdud is combined with other materials, all component prope~es must be considered. BE SURE TO CONSULT THE LATEST VERSION OF THE MSDS. MATERIALSAFETY DATA SHEETS ARE AVAlLABLE FROM HARRIS Products Group. salesinfo@iianis.m 51 3-754-2000 WWW. h a r r i ~ ~ r ~ d ~ ~ t S a r ~ ~ D . ~ ~ m STATEMENT OF LIABILITY-DISCLAIMER To the best of the Harris Roducb Group knowledge, the information and recommendations contained in this publication are reliable and accurate as ofthe date prepared. However, accuracy, suitability, or completeness are not guaranteed. and no warranty, guarantee, or representation, expre& or implied, is made by Harris Products Group as to the absolute corredness or sufficiency of any representation contained in this and other publications; Harris Products Group assumes no responsibility in connection therewith; nor can it be assumed that all acceptable safety measures are contained in this and other publications, or that other or additional measures may not be required under palticular or exceptional conditions or urcumstances . Data may be changed from time to time. PART I What is the material and what do I need to know in an emergency? I. PRODUCT IDENTIFICATION TRADE NAME (AS LABELED): CHEMICAL NAMUCLASS: SYNONYMS: PRODUCT USE: DOCUMENT NUMBER: SUPPLIERIMANUFACTURER'S NAME: ADDRESS: EMERGENCY PHONE: BUSINESS PHONE: DATE OF PREPARATION: HARRIS 10, AL-BRAZE 1070, AL-BRAZE EC FLUX Alkali Metal Halide Powder ALUMINUM Brazing and Welding Flux Metal-Working Operations 01 33 HARRIS PRODUCTS GROUP 4501 Quality Place, Mason, Ohio 45040 CHEMTREC: 1-800-424-9300 1 -5 1 3-754-2000 July 12,2007 2. COMPOSITION and INFORMATION ON INGREDIENTS CHEMICAL NAME I ms# I %wk I3 ACGlH nv I STEL I PEL XURE LIMITS IN AIR J OTHER I Alkali Metal Chlorides: Lithium Chloride Potassium Chloride Sodium Chloride 75-90 7447-41 8 744747 7647-1 4-5 Lithium Fluoride 778424-4 415 2.5, :(Not N: 2:. "1 NlOSH REL: 2.5 Classifiable as a Human I ( DFG k4K: 2.5 rota1 Carcinogen) respirable dust fraction) (exposure llmi are for Zinc Chloride fume) 2(vacated 50 NlOSH REL: I989PEL) ( STEL W A = i = 2 Carcinogen: EPA-D I ALUMINUM FLUXES EFFECTIVE DATE: June 19,2003 PAGE 1 OF 8 <<>> NE = Not Established. NIC = Notice of Intended Change mppd = Millions of Pamdes per Cubic Foot See Secti~ 16 for Definilions of Terms Used. NOTE (1): The ACGlH has an established exposure limit for Welding Fumes, Not OVlelwise Classified. The Threshold Limk Value is 5 mg/m3. NIMH dassifies welding fumes as carcinogens. Single values shown are maximum, unies3 otherwise Mted. NOTE (2): ALL W M l S required infomation is induded in appropriate sections based on the ANSI Z400.1-1998 fonat. This product has been dassifd in accordance with the hazard criteria of the CPR and the MSDS contains all the information required by the CPR. 3. HAZARD IDENTIFICATION EMERGENCY OVERVIEW: These products consist of odorless white or pink powers (A-braze 1070 & EC is white) (HARRIS 10 is pink). This product is neither flammable nor reactive under normal circumstances. If involved in a fire, the components of this product can decompose to release corrosive hydrogen fluoride. This product and its decomposition ~roducts can severelv irritate the skin. eves. and anv other contaminated tissue. Emergency responders must wear the b p e r , - ~ -~~ protebive equipment suiable for the iituation to which they are responding. 1 SYMPTOMS OF OVER-EXPOSURE BY ROUTE OF EXPOSURE: r i The most significant routes of over-exposure for this product are by HAZARDOUS MATERIAL INFORMATION contact with skin, eye contact, or inhalation of this product SYSTEM INHALATION: If this product is inhaled, it may imtate and burn the nose, throat, and respiratory system. ~ymptorns of inhalation over- HEALTH (BLUE) 2 exposure may include coughing, sneezing, and difficulty breathing. Inhalation over-exposure to Zinc Chloride fumes can cause metal fume fever. Severe inhalation over-exposure to Zinc Chloride (a component of this product) can cause life-threatening lung injury, such as FLAMMABILITY '" o pulmonary edema and pneumonitis. CONTACT WITH SKlN or EYES: Depending on the duration and concentration of over-exposure, skin contact with this product can severely imtate the skin. Repeated or prolonged skin over-exposure REACTIVITY m o w 0 to this product may result in dermatitis (red, dry, itchy skin). Depending on the duration and concentration of over-exposure, eye contact with this product may irritate or burn the eyes. Eye over- exposure can cause tearing and redness. PROTECTIVE EQUIPMENT SKlN ABSORPTION: Hydrogen fluoride (a possible decomposition product) is extremely corrosive and a poison by all routes of entry. Hydrogen fluoride can penetrate the skin and produce bums which may not be immediately painful or visible; the bums impact the lower layers of skin and bone tissue. Hydrogen fluoride exposures involving 20 percent of the body or more can be fatal through systemic fluoride ri Section 8 poisoning. For routine industfial applications INGESTION: Ingestion is not anticipated to be a likely route of occupational exposure for this product. If this product is swallowed (especially in large amounts), it may irritate the mouth, throat, and other tissues of the digestive system. Initial symptoms may include nausea, vomiting, burning sensation in the esophagus and stomach, blurred vision, ringing in the ears, weakness, staggering, and tremor. Later symptoms may include abdominal pain, bloody diarrhea, convulsions, high blood pressure, and coma. Ingestion of only a few grams of Zinc Chloride (a component of this product) may be fatal. Chronic ingestion over-exposure may cause mottling of tooth enamel, gastrointestinal discomfort, weakness, drowsiness, tremors, loss of appetite, slurred speech, vomiting, diarrhea, and hardening or abnormal denseness of the bones. Kidney function can be impaired by lithium salts. Severe ingestion over- exposure may be fatal. INJECTION: Though not anticipated to be a likely mute of occupational exposure for this product, injection of this product (via punctures or lacerations by a contaminated object) may cause local reddening, tissue swelling, and discomfort in addition to the wound. HEALTH EFFECTS OR RISKS FROM OVER-EXPOSURE: An Explanation in Lay Terms. Symptoms associated with over-exposure to this product are as follows: ACUTE: Symptoms of inhalation over-exposure may include coughing, sneezing, and difficulty breathing. Severe inhalation over-exposure to Zinc Chloride (a component of this product) can cause life-threatening lung injury, such as pulmonary edema and pneumonitis. Depending on the duration and concentration of over-exposure, skin contact with this product can severely irritate the skin. Depending on the duration and concentration of over-exposure, eye contact with this product can irritate or burn the eyes. Initial symptoms after ingesting large amounts of this product may include nausea, vomiting, burning sensation in the esophagus and stomach, blurred vision, ringing in the ears, weakness, staggering, and tremor. Severe ingestion over-exposure may be fatal. CHRONIC: Repeated or prolonged skin over-exposure to this product may result in dermatitis (red, dry, itchy skin). Chronic ingestion over-exposure may cause mottling of tooth enamel, gastrointestinal discomfort, weakness, drowsiness, tremors, loss of appetite, slurred speech, vomiting, diarrhea, and hardening or abnormal denseness of the bones. Chronic ALUMINUM FLUXES EFFECTIVE DATE: June 19,2003 W o n 8 PAGE 2 OF 8 <<>> over-exposure to hydrogen fluoride (a possible decomposition produd) can cause fluorosis (weakening and degeneration of bone structure and possible heart, nerve, and intestinal problems). Refer to Section 11 (Toxicological Information) for additional information regarding this product and its components. PART I I What should I do if a hazardous situation occurs? 4. FIRST-AID MEASURES SKIN EXPOSURE: If this product or its decomposition products irritate the skin, begin decontamination with running ~ater. Minimum flushing is for 15 minutes. Do not intempt flushing. If necessary, apply calcium gluconate gel (2.5% concentration) after flushing is complete. See Section 11 (Toxicological Information, Recommendations to Physicians) for more information on the use of calcium gluconate gel. Remove exposed or contaminated clothing, taking care not to contaminate eyes. Victim must seek medical attention if any adverse reaction occurs. EYE EXPOSURE: If this product enters the eyes, open victim's eyes while under gently running water. Use sufficient force to open eyelids. Have victim "roll" eyes. Minimum flushing is for 15 minutes. Do not interrupt flushing. Victim must seek immediate medical attention. INHALATION: If this product is inhaled, remove victim to fresh air. If necessary, use artifiaal respiration to support vital functions. Victim must seek medical attention if any adverse reaction occurs. INGESTION: If this product is swallowed, CALL PHYSICIAN OR POISON CONTROL CENTER FOR MOST CURRENT INFORMATION. Do not induce vomiting, unless directed by medical personnel. Have victim rinse mouth with water, if conscious. Never induce vomiting or give diluents (milk or water) to someone who is unconscious, havinq convulsions, or who cannot swallow. If vomiting occurs, lean patient forward or place on leff side (head-down position, if possible) to maintain an open airway and prevent aspiration. Victims of chemical exposure must be taken for medical attention. Rescuers should be taken for medical attention if necessary. Take copy of label and MSDS to health professional with victim. 5. FIRE-FIGHTING MEASURES FLASH POINT: Not flammable. AUTOIGNITION TEMPERATURE: Not applicable. NFPA RATING FLAMMABLE LIMITS (in air by volume, %): Lower ILEL): Not applicable. FWM IUM Upwr WELL: Not applicable FlRE EXTINGUISHING MATERIALS: This material is not flammable. Use extinguishing media appropriate for surrounding fire. @ Water S~ray: YES (for cooling) Carbon Dioxide: YES HEALTH REACTIWM Halon: YES - - Foam: YES m: YES m. Any "ABC' Class. UNUSUAL FlRE AND EXPLOSION HAZARDS: During a fire, irritating and toxic gases (e.g., hydrogen fluoride, alkali metal oxides, fluorine, and chlorine) OTHER may be generated. Explosion Sensitivitv to Mechanical Im~ad: Not sensitive. Exolosion Sensitivitv to Static Discharcle: Not sensitive. SPECIAL FIRE-FIGHTING PROCEDURES: NIA 6. ACCIDENTAL RELEASE MEASURES SPILL AND LEAK RESPONSE: Uncontrolled releases should be responded to by trained personnel using pre-planned procedures. Proper protective equipment should be used. In case of a spill, clear the affected area and protect people. In the event of an incidental release of this product, personnel should wear gloves, safety glasses (or goggles), and face shield during clean up. In the event of a non-incidental release, minimum Personal Protedie Equipment should be Level B: triplegloves (rubber gloves and nitrile gloves over latex gloves), chemical resistant sult and boots, hard-hag and SelfGontained Breathing Apparatus. Sweep up spilled powder carefully, avoiding the generation of airborne dust. Decontaminate the area thoroughly. Place an spill residues in a suitable container and seal. Dispose of in accordance with Federal, State, and local hazardous waste disposal regulations (see Section 13, Disposal Considerations). PART III HOW can I prevent hazardous sihrationmm occurring 7. HANDLING and STORAGE ALUMINUM FLUXES EFFECTIVE DATE: June 19.2003 PAGE 3 OF 8 <<>> WORK PRACTICES AND HYGIENE PRACTICES: As with all chemicals, avoid getting this product ON YOU or IN YOU. Wash thoroughly after handling this product. Do not eat or drink while handling this material. Avoid generating airborne dust of this product. Remove contaminated clothing immediately. STORAGE AND HANDLING PRACTICES: All employees who handle this material should be trained to handle it safely. Empty containers may contain residual powder; therefore, empty containers should be handled with care. Store this product in a cool, dry location, away from direct sunlight, sources of intense heat. Store away from incompatible chemicals (see Section 10, Stability and Reactivity). Material should be stored in secondary containers or in a diked area, as appropriate. Storage and use areas should be covered with impervious materials. Keep container tightly closed when not in use. Inspect all incoming containers before storage to ensure they are properly labeled and not damaged. PROTECTIVE PRACTICES DURING MAINTENANCE OF CONTAMINATED EQUIPMENT: Follow practices indicated in Section 6 (Accidental Release Measures). Make certain that application equipment is locked and tagged-out safely. Decontaminate equipment using soapy water before maintenance begins. Collect all rinsates and dispose of according to applicable Federal, State, or local procedures. 8. EXPOSURE CONTROLS - PERSONAL PROTECTION VENTILATION AND ENGINEERING CONTROLS: Use with adequate ventilation to ensure exposure levels are maintained below the limits provided in Section 2 (Composition and Information on Ingredients). Exhaust directly to the outside, taking necessary precautions for environmental protection. Prudent practice is to ensure eyewasNsafety shower stations are available near areas where this product is used. RESPIRATORY PROTECTION: Maintain airborne contaminant concentrations below guidelines listed in Section 2 (Composition and Information on Ingredients) if applicable. If respiratory protection is needed, use only protection authorized in 29 CFR 1910.134 or applicable State regulations. Use supplied air respiration protection if oxygen levels are below 19.5% or are unknown. EYE PROTECTION: Safety glasses or goggles. HAND PROTECTION: Wear natural rubber, neoprene, or nitrile rubber gloves for routine industrial use. BODY PROTECTION: None needed for normal circumstances of use. Use body protection appropriate for task (i.e., apron, coveralls, and chemical resistant boots). 9. PHYSICAL and CHEMICAL PROPERTIES RELATIVE VAPOR DENSITY (air = I): Not applicable. EVAPORATION RATE (nBuAc = I): Not applicable. SPECIFIC GRAVITY (water = I ) : Not applicable. FREUINGIMELTING POINT: Not established. SOLUBILITY IN WATER: Moderately soluble. BOILING POINT: Not established. VAPOR PRESSURE, mm Hg @ 24OC: Not established. pH: Not applicable. ODOR THRESHOLD: Not applicable. COEFFICIENT OF OIUWATER DISTRIBUTION (PARTITION COEFFICIENT): Not established. APPEARANCE AND COLOR: HARRIS 10 is an odorless, pink powder. Al-braze EC and Al-Braze 1070 is an odorless, white powder. HOW TO DETECT THIS SUBSTANCE (warning properties): The appearance may act as a distinguishing characteristic of this product. 10. STABILITY and REACTIVITY STABILIN: Stable. DECOMPOSITION PRODUCTS: Hydrogen fluoride, alkali metal oxides, fluorine, and chlorine. MATERIALS WITH WHICH SUBSTANCE IS INCOMPATIBLE: Strong oxidizers, strong acids, reactive interhalogens. HAZARDOUS POLYMERIZATION: Will not occur. CONDITIONS TO AVOID: Extreme temperatures, moisture, incompatible materials. ALUMINUM FLUXES EFFECTIVE DATE: June 19,2003 PAGE 4 OF 8 <<>> PART IV 1s there any other useful information about this material? 1 I. TOXICOLOGICAL INFORMATION TOXICITY DATA: Human toxicological data are available for the components of this product listed in Section 2 (Composition and Information on Ingredients). Other data for animals are available but are not presented in this Material Safety Data Sheet. LITHIUM CHLORIDE: POTASSIUM CHLORIDE (continued): SODIUM CHLORIDE (continued): DNA Inhibition (Hela cell, human) = 70 TDLo (oral, woman) = 60 mgkgl days; TDLo (intraplacental, woman) =27 mykg/ 15 mmOVL gastrointestinal tract, bloc4 em& weeks pregnant; reproductive effeds LDLo (oral, human) = 200 mglkgl3 days LDLo (oral, man) = 20 mglkg; cardiovascular, aNCCHLORIDE: TDLo (oral, human) = 243 mglkgl 13 days; gastrointestinal tract, blood eLcts DNA Inhibition Sptem (human, lymphocyte) central nervous system, gastrointestinal SODIUM CHLORIDE: = 0.360 mmoVL effects DNA Inhibition (fibroblast, human) = 125 TCLo (inhalaoon, man) = 4800 me/m3/ 30 POTASSIUM CHLORIDE: mmcUL minutes; pulmonary effects LDLo (oral, infant) = 938 mglkg/ 2 days TCLo (inhalation, human) = 4800 mglm3/ 3 hours SUSPECTED CANCER AGENT: The components of this product are not found on the following lists: FEDERAL OSHA Z I-IST, NTP, IARC, and CAUOSHA, and therefore are not considered to be, nor suspected to be, cancer-causing agents by these agencies. IRRlTANCY OF PRODUCT: This product may severely irritate or burn contaminated tissue. SENSITIZATION TO THE PRODUCT: No component of this product is known to be a sensitizer with prolonged or repeated use. REPRODUCTlVE TOXICITY INFORMATION: Listed below is information concerning the effects of this product on the human reproductive system. Muta~enicity: This product is not reported to produce mutagenic effects in humans. Human mutation data are available for Lithium Chloride and Zinc Chloride (components of this product); these data were obtained during clinical studies on specific human tissues exposed to high doses of these compounds. Animal mutation data are available for Potassium Chloride Sodium Chloride (a component of this product); these data were obtained during dinical studies on specjfic animal tissues exposed to high doses of these compounds. Embrvotoxicity: This product is not reported to produce embryotoxic effects in humans. Teratoqenicity: This product is not reported to cause teratogenic effects in humans. Clinical studies on test animals exposed to relatively high doses of Lithium Chloride, Sodium Chloride, and Zinc Chloride (components of this product) indicate teratogenic effects. Re~roductive Toxicity: This product is not reported to cause adverse reproductive effects in humans. Clinical studies on test animals exposed to relatively high doses of Lithium Chloride, Sodium Chloride, and Zinc Chloride (components of this product) indicate adverse reproductive effects. A mutawn is a chemical which causes permanent changes to genetic material (DNA) such that the changes will propagate through g€?nefational lines. An embmtoxin is a chemical which causes damage to a developing embryo (i.e. within the first eight weeks of pregnancy in humans), but the damage does not propagate across generational lines. A teratoaen is a chemical which causes damage to a developing fetus, but the damage does not propagate acms generational lines. A ~~ruductive toxin is any substance which interferes in any way with the reproductive process. BIOLOGICAL EXPOSURE INDICES: Currently, there are Biological Exposure Indices (BEls) assodated with Lithium Fluoride (a component of this product, as a fluoride). MEDICAL CONDITIONS AGGRAVATED BY EXPOSLIRE: Dermatitis, other skin disorders, and respiratory conditions may be aggravated by over-exposure to this product. RECOMMENDATIONS TO PHYSICIANS: Treat symptoms and eliminate over-exposure. In the event of over-exposure to this product, all personnel providing treatment must be gloved. If there is a possibility of contamination by hydrogen fluoride (a decomposition product), treatment recommendations for contamination are as follows: Skin Contact After 15 minute water flush (if flush has not yet been done). apply calcium gluwnate gel (2.5% concentration) until pain has subsided, but not longer than 30 minutes. If pain lasts longer than 15 minutes, proceed with calcium glumate injections. Eye Contact: After 15 minutes water flush (iflush has not been done), flush eyes with 1 % calcium gluwnate gel in normal, sterile saline. Inhalation: Provide 100% oxygen, followed by inhalation of a mist containing 2.594 calcium gluconate in saline solution. Watch for pulmonary edema. Ingestion: Gastric lavage with lime water or milk. ALUMINUM FLUXES EFFECTIVE DATE: June 19,2003 PAGE 5 OF 8 <<>> 12. ECOLOGICAL INFORMATION ALL W R K PRACTICES MUST BE AIMED AT ELIMINATING ENVIRONMENTAL CONTAMINATION. ENVIRONMENTAL STABILITY: The components of this product will decompose under normal environmental condlions. Additional environmental data are available as follows: UTHIUM CHLORUIE: Log Kow = -2.66: Water solubility = 1 911.3 mL (cold water), I gl0.8 mL @oiling water). LITHIUM FLUORIDE: Water solubility = 0.13 g/ 100 mL (25%). POTASSIUM CHLORIDE: Water solubility = 34.281 100 mL (20°C), 1 gl 2.8 mL. 1 911.8 mL (boiling). SODIUM CHLORIDE: Water solubility = 37 gl100 mL (0°C); Log Kow = -3.0. ZINC CHLORIDE: Water solubility: 432 gll00 mL (25"C), 614 g/ 100 mL (1 00%). Zinc can persist indefinitely as a cation. Radioadive zinc e n ) has been found to concentrate in plants and milk. Acute Hazard Level Threshold: For vegetables and olher crops - 750 ppm (Zn). EFFECT OF MATERIAL ON PLANTS or ANIMALS: This product can be harmful to plant and animal li. Specific data on test animals are available, but are not presented in this Material Safely Data Sheet. EFFECT OF CHEMICAL ON AQUATIC LIFE: Large releases of this product may be harmful or fatal to exposed aquatic life. ZINC CHLORIDE: Acute Hazard Level Threshold: For fish - 0.1 pprn (Zn) Odoriess zinc poisoning causes inflamed gills in fish. Laboratory studies of Atlantic salmon, rainbow @out, carp, and goldfish have shown avoidance readions by these fish to zinc in water. Radiiadlve dnc $Zn) has been found to mnc8nlrate in aquatic life. 13. DISPOSAL CONSIDERATIONS PREPARING WASTES FOR DISPOSAL: Waste disposal must be in accordance with appropriate Federal, State, and local regulations. This product, if unaltered by use, may be disposed of by treatment at a permitted facility or as advised by your local hazardous waste regulatory authority. EPA WASTE NUMBER: Not applicable. 14. TRANSPORTATION INFORMATION 0 PROPER SHIPPING NAME: Comive Solid, n.0.s. (Zinc chloride, Lithium chloride - anhydrous mixture) HAZARD CLASS NUMBER and DESCRIPTION: 8 (Corrosive) UN lDENTIFlCATlON NUMBER: UN 1759 PACKING GROUP: II DOT LABEL(S) REQUIRED: CORROSIVE NOTE: Exception for Class 8 for net capacity of 2.2 pounds or less on inner packaging. Refer to 49 CFR 173.154 for additional information. NORTH AMERICAN EMERGENCY RESPONSE GUIDEBOOK NU'MBER (1996): 154 MARINE POLLUTANT: The components of this product are not designated by the Department of Transportation to be Marine Pollutants (49 CFR 172.1 01, Appendix 0). TRANSPORT CANADA TRANSPORTATION OF DANGEROUS GOODS REGULATIONS: THIS MATERIAL IS CONSIDERED AS DANGEROUS GOODS. Refer to above information for Canadian shipments. 15. REGULATORY INFORMATION SARA REPORTING REQUIREMENTS: The components of this product are subject to the reporting requirements of Sections 302,304, and 31 3 of Tile Ill of the Superfund Amendments and Reauthorization Act. (1 Zinc Chloride I No I Yes I Yes ( as Zinc Compound) SARA THRESHOLD PLANNING QUANTITY: Not applicable. TSCA INVENTORY STATUS: The components of this product are listed on the TSCA Inventory. CERCLA REPORTABLE QUANTITY (RQ): Zinc Chloride = 1000 Ibs. OTHER FEDERAL REGULATIONS: Not applicable. ALUMINUM FLUXES EFFECTlVE DATE: June 19,2003 PAGE 6 OF 8 <<>> 15. REGULATORY INFORMATION (Continued) STATE REGULATORY INFORMATION: The components of this product are covered under specific State regulations, as denoted below Alaska - Designated Toxic and Hazardous MlchlganCrlUcal Materiala Reglstec Zinc Pennsyhrania - Hazardous Substance Lit: Substances: Zinc Chloride Fume. Compounds. Zinc Chlo~ide. California - Pennlssible Exposure L i m b Minnesota - Lit of Haardous Rhode Island - Hazardous Substance List for Chemlcal Contaminants: Zinc Substances: Zinc Chloride Fume. Zinc Chloride Fume. Chloride Fume. Missouri - Employer InformatloruToxlc Texas - Hazardous Substance L k Zinc Florida - Substance L M Zinc Chloride Substance L i Zinc Chloride. Chloride Fume. Fume. New Jersey - Rlght to Know Hazardous West Virginia - Hazardous Substance Ust: Illinois - Toxic Substance list: Zinc Substance Llst: Zinc Chloride. Zinc Chloride Fume. Chloride Fume. North Dakota - List of Hazardous Wmeonsln - Toxic and Haranlow Kansas - Section 3021313 List None. Chemicals, Reportable Quantities: Substanoes: Zinc Chloride Fume. Massachusetis - Substance List Zinc Zinc Chloride. Chloride Fume. CALIFORNIA SAFE DRINKING WATER AND TOXIC ENFORCEMENT ACT (PROPOSITION 65): The components of this product are not on the California Proposition 65 lists. WARNING: This product when used may produce fumes or gases containing chemicals, known to the State of California to cause cancer, andlor birth defects (or other reproductive harm) LABELING (Precautionarv Statementsk WARNING! MAY BE FATAL IF SWALLOWED. IRRITATING IF INHALED. CAUSES SKIN AND EYE IRRITATION. Do not taste or swallow. Do not get on skin or in eyes. Avoid breathing airborne dust. Keep container closed. Use only with adequate ventilation. Wash thoroughly after handling. Wear gloves and goggles, as appropriate. FIRST-AID: In case of contact, immediately flush skin or eyes with plenty of water for at least 15 minutes while removing contaminated clothing and shoes. If inhaled, remove to fresh air. If ingested, do not induce vomiting. Get medical attention. IN CASE OF FIRE: Use water fog, dry chemical, C02, or 'alcohol" foam. IN CASE OF SPILL: Sweep up spilled powder carefully, avoiding the generation of airborne dust. Place residue in suitable container and seal. Consult Material Safety Data Sheet for additional information. See American National Standard 249.1 Safely in Welding, Cutting, and Allied P r o m s , published by the American Welding Society, 550 N.W. LeJeune Road, Miami, Florida 33126. OSHA Safety and Health Standards, 29 CFR 1910, available from the U.S. Government Printing Office, Superintendent Office, P.O. Box 371954, Piburgh, PA 15250-7954. TARGET ORGANS: Skin, eyes, respiratory system. WHMlS SYMBOLS: D2B: Materials Causing Other Toxic Effectsfroxic Material. E: Corrosive Material DATE OF PRINTING: -- - - -- -- - - 16. OTHER INFORMATION July 12,2007 ressed or implied, is made by Hams Products Gmup. as to the absolute correctness or lications; Hams Products Group. assumes no responsibility in connection therewith; nor be required under particular or exceptional conditions or circumstances. Data may be ALUMINUM FLUXES EFFECTIVE DATE: June 19,2003 PAGE 7 OF 8 <<>> DEFINITIONS OF TERMS A large number of abbreviations and aaonyms appear on a MSDS. Some ! of these, which are commonly used, indude the following: CAS R This is the Chemical Ahstrad S e ~ c e Number, which uniquely idel dties each constituent EXPOSURE LIMITS IN AIR: FWMABIUTY LIMITS IN AIR: ACGlH - American Conferen- of Governmental lndustnal rnienish, a Much of the information related to fire and explosion is derived fmm the pmkssional associaticn which establishes exposure limits. National Fire Pmtedon Assodation (NFPA). F l a s h - Minimum IARC-International Agency for Research on Cancer TLV - Threshold temperature at whid a liquid gives off suRdent vapors to fam an Limit Value - an airborne concentration of a substance, which represents ignitable mixture with air. Autoionition Temoerature: The minimum condiions under which it is generally believed that nearly all waders, temcerature reauired to ink& combustion in air with no other source of may be repeatedly exposed without adverse effect. The duration must be &6&. - > ~- - the lows-b&nt of vapor in air, by volume, that will considered, induding the 8hour T i WeigMed Average F A ) , the 1 5 explode or ignite in the presence of an ignition source. !J& - the hghest minute Short Term Exposure Limit, and the instantaneous Ceiling Level percent of vapor in air, by volume, that will explode or ignite in the (C). Skin absorption effects must also be considered. presence of an ignition source. OSHA - U.S. Ocarpatlonal Safety and Health Administration. TOXICOLOGICAL INFORMATION: PEL - Permissible Exposure limit - This exposure value means exacUy Human and Anlmal Toxicology: Possible heah hazards as derived the same as a TLV, except that it is enfarceable by OSHA. The OSHA from human data, animal studies, or from the results of studies with Permissible Ex$~sure Limits are based in the 1989 PELs and the June. similar compounds are presented. Definitions of some terms wed in this 1993 Air Contaminants Rule (Federal Remister: 58: 35338-35351 and 58: section are: L& - Lethal Dose (solids & liquids) which kilk 50% of the 401 91). Both the current PELS and the vacated PELs are indicated. The exposed animals; LC& - Lethal Concentration (gases) which ldlls 50% of phrase, Vacated 1989 PEL," is placed nexi to the PEL, which was the exposed animals; ppm concentration express6d in pa& of material vacated by Court Order, IDLH - Immediately Dangerous to Life and per million parts of air or water; mglms concentration expmsed in weight Health -This level represents a concentration from which one can escape of substanoe per volume of air; w g quantity of material, by weight, wlthin 3Gminutes without suffering escapepreventing or permanent administered to a test subject, based on their body weigM in kg. Other injury. The DFG - MAK is the ~epublic of ~ermanfs~akmum Exposure measures of toxicity indude TDLo, the lowest dose to cause a symptom Level, similar to the U.S. PEL. NlOSH is the National Institute of and TCLo the lowest mncenbation to cause a symptom; TDo, LDLo, Ocarmtional Safety and Health, which is the research arm of the U.S. and LDo, or TC. TCo, LCLo, and LCo, the lowest dose (or conoentration) ~ccu&ional safety and Health Administration (OSHA). NlOSH issues to cause lethal or toxic efkds. Cancer Information: The sources are: exposure guidelines called Recommended Exposure Levels (RELs). lARC - the lntematlonal Agency for Research on Cancer. NTP - the M e n no ewosure guidelines are established; an enUy of NE is made for National Tmicology Program, RTECS - the RegisLry of Toxic Effects of reference. NTP- National Toxicology Program Chemical Substances, OSHA and CAUOSHA lARC and NTP rate chemicals on a scale of decreasing potential to cause human cancer with HAZARD RATINGS: HAZARDOUS MATERIALS IDENTIFICATION SYSTEM: m: 0 (minimal acute or chronic Wosure hazard); 1 (slight acute or chronic exposure hazard); 2 (moderate acute or signilicant chronic eqwsure hazard): 3 (severe aarte exposure hazard; onetime overexposure can result in permanent injury and may be fatal); 4 (exbeme acute exposure hazard; onetime overexposure can be fatal). Flammabili Hazard: 0 (minimal hazard); 1 (materials that require substantial preheating before burning); 2 (combustible liquid or solids; liquids with a flash point of 3893°C [10G20Oofl); 3 (Class 18 and IC Rammable liquids with flash points below 38°C [IWfl); 4 (Class IA flammable liquids with flash points below 23°C [73"F] and boiling points below 38°C [lOO°F]. Readivitv Hazard: 0 (normally stable); 1 (material that can become unstable at elevated temperatures or which can react slightly with water); 2 (materials that are unstable but do not detonate or which can read violently with water); 3 (materials that can detonate when initiated or which can read explosively with water); 4 (materials that can detonate at normal temperatures or pressures). NATIOW FIRE PROTECTION ASSOCIATION: Health Hazaa: 0 (material that on exposure under fire wnditiom would offer no hazard beyond that of ordinary combustible materials); 1 (materials that on exposure under fire condiions could cause irritation or minor residual injury); 2 (materials that on intense or continued exposure under fire conditions could muse temporary incapacitation or possibb residual injury); 3 (materials that can on short exposure could cause serious temporary or residual injury); 4 (materials that under very short exposure causes death or major midual injury). -: Refer to definitions far 'Hazardous Materials rankings from 1 to 4. Subranldngs (2A. 28, etc) are also used. Other Information: BE1 - ACGlH Biological Exposure Indioes, represent the levels of determinants which are most likely to be observed in specimens cdleded from a healthy worker who has been exposed to chemicals to the same extent as a worker with inhalation exposure to the TLV. Ecological Information: EC is the effect concentration in water. BCF = Bioconceniration Fador, which is used to determine if a substance will concentrate in liforms which consume contaminated plant or animal matter. CoeRaent of OiWater Distribution is represented by log K, or log K, and is used to a s s a substance's behavior in the environment. REGULATORY INFORMATION: This section explains the impact of various laws and regulations on the material. U.S.: EPA is the U.S. Environmental Protection Agency. DOT is the U.S. Department of Transportation. SARA is the Superfund Amendments and Reauthorization Act. TSCA is the U.S. Toxic Substance Control A d CERCLA (or Supetfund) refers to the Comprehensive Environmental Response, Compensation, and Liability Act. Labeling is per the American National Standards Institute (ANSI 2120.1). CANADA: CEPA is the Canadian Envimnmental Protection Act. WHMlS is the Canadian W-ce Hazardous Materials Information System. TC is Transporl Canada. DSLfNDSL are the Canadian DomestidNon-Domestic Substances Lists. The CPR Is the Canadian Ploduct Regulations. This section also indudes infurmation on the precautionary warnings, which appear, on the materials package label. Identication System". ALUMINUM FLUXES EFFECTIVE DATE: June 19,2003 PAGE 8 OF 8 <<>> fuming bronze and nickel preheating the rod end and dipping the 600 Powder flux has an active A liquid flux for use with aluminum soldering. Use with Al-Solder 500. Works to join aluminum to dissimilar metals. USA STAY-CLEAW@ PASTE FLUX WE 1" An active soldering flux formulated for use with tin-lead, tin-antimony, and tin-silver solders. Superior flux for most metals, copper, brass, bronze, steel, stainless steel, galvanized, MonelW, Not recommended for aluminum, magnesium, or titanium. Not recommended for electrical or electronic applications. USA * A general purpose zinc ch\orida flux for soldering with all sofl soldem use W\UI tin-lead solder, STAY-CLEAR@ LIQUID FLUX WE ll tin-antimony solder, Stay-Brite' solder, for Soldering virtually all metals, except aluminum, magnesium or titanium. Not recommended for use in electrical or electronic applications. ons that can result In voids and leaks. in the form of a very fine powder. Solar Flux is ol preferred) and brushed on the weld joint. R is Joint from oxygen, dissipate heat and unwanted It will aid in the flow of filler metal over base metal xidation and heat scale. less steel, (except 309, 310), precipitation hardening steels, chrome-moly steels with nickel content below 25%. T h e H a r r i s P r o d u c t s G r o u p - 1 . 8 0 0 . 7 3 3 . 4 0 4 3 w w w . h a r r i s p l o d u c t s g r o u p , c o m "4 <<>> MATERIAL SAFETY DATA SHEET Prepared to U.S. OSHA. CMA, ANSI and Canadian WHlMlS Standards. This lMatefial Safety Date Sheet is offeredpursuant lo OSHA's H a m Communication Standard (29 CFR 1910.1200). Other government regulations must be r e v i e d for applicability to th8~e produds WARNING: PRODUCT COMPONENTS PRESENT HEALTH AND SAFETY HAZARDS. READ AND UNDERSTAND THIS MATERIAL SAFETY DATA SHEET (WS.DS.). ALSO, FOLLOW YOUR EMPLOYER'S SAFETY PRACTICES. Thls product may contain Chmium andlor Nlckel whlch are I ' i by OSHA, NTP, or IARC as being a callcinogen or potentla1 minogen. Use of thlr product may expose you or others to fumes and g m at levels exceeding those established by the American Conlerence of Governmental Industrial HyglenlsEs (ACGIH) or the Oaupational Selety and HealUl Administration (OSHA) The information contained herein relates only to the spedc prcdud. If the pmdud is combined wiU1 other materials, all component properties must be considered. BE SURE TO CONSULT THE LATEST VERSION OF THE MSDS. MATERIAL M E W DATA SHEETS ARE AVAllABLE FROM Harrls Products Group salesinfotaianis.wtq 513754-2000 www.iwharris.com STATEMENT OF LlABlLIM-DISCLAIMER To the best of the Hams Pmduds Group knowledge, the information and recommendations contained in this publication are reliable and accurate as of the date prepared. However, accuracy, suitability, or completeness are not guaranteed, and no warranty, guarantee, or representation, expressed or implied, is made by Harris Prcduds Group. as to the absolute correctness or sufficiency of any representation contained in this and other publications; Hanis Products Group assumes no responsibility in connection therewith; nor can it be assumed that all acceptable safety measures are mntained In this and other publications, or that other or additional measures may not be required under particular or exceptional conditions or circumstanQs . Data may be changed from time to lime. PART I What is the material and what do I need to know in an emergency? I. PRODUCT IDENTIFICATION TRADE NAME (AS LABELED): STAY CLEAN@ LIQUID SOLDERING FLUX CHEMICAL NAMEICLASS: Zinc ChloridelAmmonium Chloride Solution SYNONYMS: Not Applicable PRODUCT USE: Metal-Soldering Operations DOCUMENT NUMBER: 0099 SUPPUERMANUFACTURER'S NAME: Harris Products Group. ADDRESS: 4501 Quality Place, Mason, Ohio 45040 EMERGENCY PHONE: CHEMTREC: 1-800-4249300 BUSINESS PHONE: 51 3-7542000 FAX 513-754-8778 DATE OF PREPARATION: July 13,2007 2. COMPOSITION and INFORMATION ON INGREDIENTS (as Hydrogen Chloride) NE = Not Established. NOTE (1): See Section 16 for Definitions of Terms Used. AU- WHMlS required information is included in appropriate sections based on the ANSl 2400.1-1998 format This produd has been classified in accordance with the hazard criteria of the CPR and the MSDS contains all the information requlred by the CPR. STAY CLEAN@ LIQUID SOLDERING FLUX MSDS DATE: July 1,2004 PAGE 1 OF 9 <<>> 2. COMPOSITION and INFORMATION ON INGREDIENTS (Continued) NE = Not Established. See Section 16 for Definitions of Terms Used. NOTE (1): ALL W M I S required information is included in appropriate sections based on the ANSI 2400.1-1998 format. This produd has been dassifed in accordance with the hazard criteria of the CPR and the MSDS contains all the informaeon required by the CPR. 3. HAZARD IDENTIFICATION acidic and can initate and burn the skin, eyes, and any other contaminated tissue. This product is neither flammable I EMERGENCY OVERVIEW: This product is a clear, colorless liquid, possessing a slight, sweet odor. This material is nor reactive under normal circumstances; however, it may generate flammable hydrogen gas upon contact with metals. responding. I Emergency responders must wear the proper personal protective equipment suitable for the situation to which they are - ----- SYMPTOMS OF OVER-MPOSURE BY ROUTE OF EXPOSURE: The most significant routes of over-exposure for this product are by contact with skin, eye contact, or inhalation of mists or sprays generated by this produd. The symptoms of overexposure to this product, by route of enhy, are as follows: INHALATION: If vapors, mists, or sprays of this product are inhaled, they can irritate and bum the nose, throat, and respiratory system. Symptoms of inhalation over-exposure may include sore throat, choking, coughing, and difficulty breathing. Prolonged or repeated over-exposure may cause burns and ulcers to the nose and throat, dental erosion, bronchitis, and stomach pains. It has been reported that a worker developed asthmatic symptoms after performing S~ldering work with a flux containing.Ammonium and Zinc Chlorides (components of this product). It has been reported that inhalation of Methanol (a component of this product) vapors in high concentrations can cause blindness. Severe inhalation overexposure may cause pulmonary edema (a life-threatening accumulation of fluid in the lungs) or pneumonitis. Symptoms of pulmonary edema (e.g., shortness of breath, chest pains) can PROTECTIVE EQUIPMENT I D be delayed for several hours after exposure. Severe inhalation of vapors or I I I fumes (as may occur if individuals are exposed in poorly ventilated areas, such as confined spaces) may be harmful. CONTACT WITH SKIN or EYES: Depending on the duration and concentration of overexposure, skin contact with this product can initate and bum the skin. Repeated or prolonged over-exposure to this product may result in dermatitis (red, dry, itchy skin) and ulceration. Depending on the duration and concentration of overexposure, eye contact with this product can irritate and bum the eyes. Eye over-exposure can cause pain, tearing, and redness. Severe eye over-exposure may cause See Section 16 for Definition of Ratinas blindness. STAY CLEAN@ LIQUID SOLDERING FLUX MSDS DATE: July 1,2004 PAGE 2 OF 9 <<>> 3. HAZARD IDENTIFICATION (Continued) SKlN ABSORPTION: Methanol (a component of this product) is readily absorbed through the skin. Because Methanol is a minor component of this product, skin absorption is not anticipated to be a significant mute of over-exposure. INGESTION: If this flux is ingested, nausea, vomiting, and diarrhea may occur (depending on the amount of the product Swallowed). Severe ingestion exposures may result in damage to the tissues of the gastrointestinal system, and death. INJECTION: Though not anticipated to be a likely route of occupational exposure for this product, injection of this product (via punctures or lacerations by a contaminated object) may cause local reddening, tissue swelling, and discomfort in addition to the wound. HEALTH EFFECTS OR RISKS FROM OVER-EXPOSURE: An Explanation in Lay Terms. Symptoms associated with over-exposure to this product are as follows: ACUTE: Symptoms of inhalation overexposure may include sore throat, choking, coughing, dicutty breathing. Lung damage may occur after severe inhalation exposures. Depending on the duration and concentration of over-exposure, skin or eye contact with this product can irritate and bum contaminated tissue. Ingestion overexposure may be hannful or fatal. CHRONIC: Prolonged or repeated inhalation over-exposure may cause bums and ulcers to the nose and throat, dental erosion, bronchitis, and stomach pains. Repeated or prolonged over-exposure to this product may result in dermatitis (red, dry, itchy skin) and ulceration. Refer to Section 11 (Toxicology Information) for additional data. TARGET ORGANS: ACUTE: Skin, eyes, respiratory system, central nervous system. CHRONIC: Skin, respiratory system, and gastrointestinal system. PART 11 What should I do if a hazardous situation occurs? 4. FIRST-AID MEASURES Victims of chemical exposure must be taken for medical attention, if adverse health effects occur. Rescuers should be taken for medical attention, if necessary. Take copy of label and MSDS to health professional with victim. SKlN EXPOSURE: In the event of skin-over-8xposure, rinse affected area with a soap and water solution. If skin contact results in irritation, the minimum Rushing is for 15 minutes. Victim must seek medical attention if adverse health effects occur. EYE EXPOSURE: If this product enters the eyes, open victim's eyes while under gentle running water. Use sufficient force to open eyelids. Have victim "roll" eyes. Minimum flushing is for 15 minutes. Victim must seek medical attention if adverse health effects occur. INHALATION: If this product is inhaled, remove victim to fresh air. If necessary, use artificial respiration to support vital functions. INGESTION: If this product is swallowed, CALL PHYSICIAN OR POISON CONTROL CENTER FOR MOST CURRENT INFORMATION. Do not induce vomiting, unless directed by medical personnel. Have victim rinse mouth with water, if conscious. Never induce vomiting or give diluents (milk or water) to someone who is unconscious, havina convulsions, or who cannot swallow. If vomiting occurs, lean patient forward or place on left side (head-down position, if possible) to maintain an open airway and prevent aspiration. MEDICAL CONDITIONS AGGRAVATED BY EXPOSURE: Dermatitis, other skin disorders, and respiratory conditions may be aggravated by over-exposure to this product. RECOMMENDAllONS TO PHYSICIANS: Treat symptoms and eliminate overexposure. Provide oxygen, if necessary. Pulmonary function tests, chest X-rays, and nervous system evaluations may prove useful. Consultation with an ophthalmologist is recommended if eye exposure leads to tissue damage. STAY CLEAN@ I-IQLIID SOLDERING FLUX MSDS PAGE 3 OF 9 DATE: July 1,2004 <<>> 5. FIRE-FIGHTING MEASURES FLASH POINT: Not flammable. NFPA RATING AUTOIGNITION TEMPERATLIRE: Not applicable. FLAMMABLE LIMITS (in air by volume, %): Lower ILEL): Not applicable. FLAMM ILIM U ~ m r IUELl: Not applicable FlRE EXTINGUISHING MATERIALS: This material is not flammable. Use extinguishing media appropriate for surrounding fire. Water S~rav: YES (for cooling)Carbon Dioxide: YES HWTH REACTIV~N @ Halon: YES - Foam: YES Drv Chemical: YES - Other: Any "ABC" Class. UNUSUAL FlRE AND EXPLOSION HAZARDS: This product is acidic and presents a contact hazard to firefighters. During a fire, irritating and toxic gases OTHER (e.g., carbon monoxide, carbon dioxide, hydrogen chloride, nitrogen and zinc oxides, and ammonia) may be generated. Explosion Sensitivitv to Mechanical ImDact: Not sensitive. See Section 16 for Definition of Ratinqs Ex~losion Sensitivitv to Static Discharqg Not sensitive. SPECIAL FIRE-FIGHTING PROCEDURES: Incipient fire responders should wear eye protection. Structural firefighters must wear Self-Contained Breathing Apparatus and full protective equipment. Chemical resistant clothing (e.g., chemical splash suit) may be necessary. Move containers from fire area if it can be done without risk to personnel. If possible, prevent runoff water from entering storm drains, bodies of water, or other environmentally sensitive areas. 6. ACCIDENTAL RELEASE MEASURES SPILL AND LEAK RESPONSE: Uncontrolled releases should be responded to by trained personnel using pre-planned procedures. Proper protective equipment should be used. In case of a spill, clear the affected area, protect people, and respond with trained personnel. In the event of an incidental release of this product, personnel should wear gloves, safely glasses (or goggles), and face shield during clean up. In the event of a non-incidental release, minimum Personal Protective Equipment should be Level B: triplegloves (rubber gloves and nitrile gloves over latex gloves), chemical resistant suit and boots, hard-hat, and Self-Contained Breathing Apparatus. Absorb spilled liquid with polypads or other suitable absorbing material. Neutralize area with sodium bicarbonate or other agent suitable for acids. Test area with litmus paper to insure neutralization is complete. Decontaminate the area thoroughly. Place all spilled residues in a suitable container and seal Dispose of in accordance with applicable U.S. Federal, State, or local procedures and appropriate Canadian standards (see Section 13, Disposal Considerations). PART II I HOW can / orevent hazardous situations from occumna 7. HANDLING and STORAGE WORK PRACTICES AND HYGIENE PRACTICES; As with all chemicals, avoid getting this product ON YOU or IN YOU. Wash thoroughly after handling this product. Do not eat or drink while handling this material. Avoid generating splashes or sprays of this product. Remove contaminated clothing immediately. STORAGE AND HANDLING PRACTICES: All employees who handle this material should be trained to handle it safely. Empty containers may contain residual liquid; therefore, empty containers should be handled with care. Store this product in a cool, dry location, away from d~rect sunlight, sources of intense heat, or where freezing is possible. Store away from incompatible chemicals (see Section 10, Stability and Reactivity). Material should be stored in secondary containers or in a diked area, as appropriate. Storage and use areas should be covered with impervious materials. Keep container tightly closed when not in use. Inspect all incoming containers before storage to ensure they are properly labeled and not damaged. PROTECTIVE PRACTICES DURING MAINTENANCE OF CONTAMINATED EQUIPMENT: Follow practices indicated in Section 6 (Accidental Release Measures). Make certain that application equipment is locked and tagged-out safely. Collect all rinsates and dispose of according to applicable U.S. Federal, State, or local procedures and appropriate Canadian standards. STAY CLEAN" LIQUID SOLDERING FLUX MSDS PAGE 4 OF 9 DATE: July 1,2004 <<>> 8. EXPOSURE CONTROLS - PERSONAL PROTECTION VENTILATION AND ENGINEERING CONTROLS: Use with adequate ventilation to ensure exposure levels are maintained below the limits provided in Section 2 (Composition and Information on Ingredients). Exhaust directly to the outside, taking necessary precautions for environmental protection. Prudent practice is to ensure eyewashlsafety shower stations are available near areas where this product is used. RESPIRATORY PROTECTION: Maintain airborne contaminant conc@ntrations below guidelines listed in Section 2 (Composition and lnformation on Ingredients) if applicable. If respiratory protection is needed, U.S. Federal OSHA Standard (29 CFR 1910.134), applicable U.S. State regulations, or the Canadian CSA Standard 294.4-93 and applicable standards of Canadian Provinces. Respiratory Protection is recommended to be worn during welding operations. Oxygen levels below 19.5% are considered IDLH by OSHA. In such atmospheres, use of a full-facepiece pressureldemand SCBA or a full facepiece, supplied air respirator with auxiliary self-contained air supply is required under OSHA's Respiratory Protection Standard (1910.1 34-1998). The following NlOSH respiratory selection guidelines are available for Zinc Chloride Fume: CONCENTRATION RESPIRATORY PROTECTION Up to 10 mg/mJ: Dust, mist, and fume respirator or Supplied-Air Respirator (SAR). Up to 25 mglm3: Powered air-purifying respirator with dust, mist and fume filter(s) or SAR operated in a continuous-flow mode. Up to 50 mg/m3: Full-facepiece respirator with high-efficiency particulate filter(s), powered air-purifying respirator with tight-fitting facepiece and high-efficiency particulate filter@), full-facepiece Setf-Contained Breathing Apparatus (SCBA), or full-facepiece SAR. Emergency or Planned Entry into Unknown Concentrations or IDLH Conditions: Positive pressure, full-facepiece SCBA or positive pressure, full-facepiece SAR with an auxiliary positive pressure SCBA. Escape: Full-facepiece respirator with high-efficiency particulate filter(s) or escape-type SCBA. EYE PROTECTION: Safety glasses or goggles. Faceshields may be needed if operations generate splashes or sprays. HAND PROTECTION: Wear neoprene or rubber gloves for routine industrial use. BODY PROTECTION: None needed for normal circumstances of use. Use body protection appropriate for task (i.e., apron, coveralls, and chemically &stant boots). 9. PHYSICAL and CHEMICAL PROPERTIES RELATIVE VAPOR DENSITY (air = 1): 4.0 EVAPORATION RATE (nBuAc = 1): > 1 SPECIFIC GRAVlTY (water = 1): 1.32 FREEZINGMELTING POINT: Not established. SOLUBILITY IN WATER: Slightly soluble. BOILING POINT: Not established. VAPOR PRESSURE: Not established. pH: Not applicable. ODOR THRESHOLD: Not established. COEFFICIENT OF OllMlATER DISTRIBUTION (PARTITION COEFFICIENT): Not established. APPEARANCE, ODOR AND COLOR: This product is a clear, colorless liquid with a slight, sweet odor. HOW TODErECT M I S SUBSTANCE (warning properties): Litmus paper will turn red upon contact with this product. The odor may also act as a distinguishing characteristic of this product. 1 0. STABII-ITY and REACTIVITY STABILITY: Stable. DECOMPOSITION PRODUCTS: Carbon monoxide, carbon dioxide, hydrogen chloride, nitrogen and zinc oxides, and ammonia. MATERIALS WlTH WHICH SUBSTANCE IS INCOMPATIBLE: Strong oxidizers, acids, alkalis and their carbonates, hydrogen cyanide, interhalogens, ammonium nitrate, potassium chlorate, lead and silver salts. HAZARDOUS POLYMERIZATION: WIII not occur. CONDITIONS TO AVOID: Extreme temperatures, incompatible materials. PART IV IS there any other useful information about this material? 1 1. TOXICOLOGICAL INFORMATION TOXICITY DATA: Human toxicological data are available for the components of this product, as listed below. Other data for animals are available but are not presented in this Material Safety Data Sheet. HYDROCHLORlC ACID: HYDROCHLORIC ACID (continued): HYDROCHLORIC ACID: LCLo (inhalation. human) = 1300 ppml30 LCLo (inhalation, human) = 3000 ppml 5 LDLo (unreported, man) = 81 rnglkg minutes minutes STAY CLEAN@ LIQUID SOLDERJNG FLUX MSDS PAGE 5 OF 9 DATE: July 1,2004 <<>> 11. TOXICOLOGICAL INFORMATION (Continued) TOXICITY DATA (continued): METHANOL: METHANOL (continued): METHANOL (contlnuedp DNA Inhibition System (lymphocyte, human) 300 LDLo (oral, human) = 143 mglkg; eye, TCLo (inhalation, human) = 300 ppm; eye, ~ n l r a l mmoK pulmonary, gastmintestinal effects n e w s system, pulmonary effeds LDLo (oral, man) = 8422 mgkg; central nervous TDLo (oral, woman) = 4000 m&; eye. ZINC CHLORIDE: system, pulmonary, gaskcintestinal eRects pulmonary, gastrointestinal effects DNA Inhibition System (human, IymphcCyte) = TDLo (oral. man) = 3429 mglkg; eye effects TCLo (inhalation. human) = 86000 mgh3; eye, 0.360 mmoK LDLo (oral, human) = 428 ng; m t r a l nervoos pulmonary effects TCLo (inhalation, man) = 4800 ma/m31 30 system, pulmonary effects minutes; pulmonary effeds TCLo (inhalation, human) = 4800 mglm31 3 hours SUSPECTED CANCER AGENT: The components of this product are listed as follows: HYDROCHLORIC ACID: I A R W (Not Classifiable as to Cardnogenicity to Humans) ZlNC CHLORIDE: EPA-D Not Classifiable as to Human Carcinogenicity) The other components of this product are not found on the following lists: FEDERAL OSHA Z LIST, NTP, WIC, and CAUOSHA, and therefore are not considered to be, nor suspected to be, cancer-causing agents by these agencies. IRRITANCY OF PRODUCT: This product can severely imtate and bum contaminated tissue. SENSITIZATION TO THE PRODUCT: It has been reported that a worker developed asthmatic symptoms after performing soldering work with a flux containing Ammonium and Zinc Chlorides (components of this product). REPRODUCTIVE TOXICITY INFORMATKIN: Listed below is information concerning the effects of this product on the human reproductive system. Muta~enicity: This product is not reported to produce mutagenic effects in humans. Human mutation data are available for Methanol and Zinc Chloride (components of this product); these data were obtained during clinical studies on specific human tissues exposed to high doses of these compounds. Animal mutation data are available for Ammonium Chloride and Hydrochloric Acid (components of this product); these data were obtained during clinical studies on specific animal tissues exposed to high doses of these compounds. Embwotoxicity This product is not reported to produce embryotoxic effects in humans. Temtoqenicity: This product is not reported to cause teratogenic effects in humans. Clinical studies on test animals exposed to relatively high doses of Methanol and Zinc Chloride (components of this product) indicate teratogenic effects. Reproductive Toxicity: This product is not reported to muse adverse reproductive effects in humans. Clinical studies on test animals exposed to relatively high doses of Hydrochloric Acid, Methanol, and Zinc Chloride (components of this product) indicate adverse reproductive effects. A mutaaen is a chemical, which causes permanent changes to genetic material (DNA) such that the changes will propagate through generational lines. An embmtoxin is a chemical, which causes damage to a developing embryo (i.e. within the first eight weeks of pregnancy in humans), but the damage does not propagate across generational lines. A terntoan is a chemical, which causes damage to a developing fetus, but the darnage does not propagate across generational lines. A re~roductive toxin is any substance, which intetfees in any way with the reproductive p m s s . ACGlH BIOLOGICAL EXPOSURE INDICES: Currently, there is a ACGlH Biological Exposure Index (BEl) determined for the Methanol component of this product. 12. ECOLOGICAL INFORMATION ALL WORK PRACTICES MUST BE AIMED AT ELIMINAIING ENVIRONMENTAL CONTAMINATION. ENVlRONMENTAL STABILIN: The components of this product will decompose under normal environmental conditions. Additional environmental data are available as follows: HYDROCHLORIC ACID: Water solublity: 56.5 g/ 100 cc (60°C); 82.3 g/ 100 ce (0°C). METHANOL: Lcg L = -0.77. Water Solubility = Miscible. BOD (glg) = 0.76-1.12 standard dilutionlsewage seed. bthanol occurs naturally as a plant volatile and during microbial degradation of biological wastes. M e n released on land or water, it is apt to vulatiUze and biodegrade. The estimated half-life in water is 5.3 hours to 2.6 days. Methanol is highly moblle In soil. The Bioconcentration Fador for Methanol is 2.0. ZlNC CHLORIDE: Water solubility: 432 gl 100 mL (25°C). 614 gl100 mL (10O0C). Zinc can persist indefinitely as a cation. Wioactive zinc m) has been found to concentrate in plants and milk. Acute Harard Level Threshold: For vegetables and other aops - 75Qpm (Zn) EFFECT OF MATERIAL ON PLANTS or ANIMALS: This product can be harmful to plant and animal lie. Specific data on test animals are available, but are not presented in this Material Safety Data Sheet. STAY CLEAN- LIQUID SOLDERING FLUX MSDS DATE: July 1,2004 PAGE6 OF 9 <<>> 12. ECOLOGICAL INFORMATION (Continued) EFFECT OF CHEMICAL ON AQUATIC LIFE: Large releases of this product may be harmful or fatal to exposed aquatic life. Additional aquatic toxicity data are available as follows: HYDROCHLORIC ACID: HYDROCHLORIC ACID (codnued): ZINC CHLORIDE: LClm (trout) = 10 m g N 24 hours LC (Lepomrs rnawtx%is, bluegill sumh) = 3.6 Acute Hazard Level Threshold: For fish - 0.1 LC, (shrimp) = 100330 ppml 48 hours(salt m g N 4 8 hours PPm (Zn) water) LC, (Lepwnis m a ~ i ~ s / b l u e g i l l sunfish) = pH Odorless znc poisoning causes inflamed gilb In LC& (statfish) = 100.300 mgRl48 hours 3.D3.Y 96 hours fish. LC& (codde) = 33D1000 mglLI 48 hours n m (sunfish) = 96 hours/ p~ 3.61 20°C Laboratory studies of Atlantic salmon, rainbow n r n (Gambusia afinis, mosquito fish) = 282 TLm (goldfish) = 96 houd pH 41 ZO°C trout, carp, and goldfish have show pprnl96 h o u d fresh water TLm (sUddeback) = 96 houlsl pH 4.61 20°C avoidance reactions by these fish to zinc in LC, (Csrassium auratus, goldfish) = 178 mgL water. (1-2 hour survival time) Radioactive zinc $Zn) has been found to LC, (shore crab) = 240 mgRl48 hours LCyr (Pimephsles pmmelas, famead minnow) = 29.4 mg/L/ 96 hours m i r a t e in aquafic li. 13. DISPOSAL CONSIDERATIONS PREPARING WASTES FOR DISPOSAL: Waste disposal must be in accordance with appropriate U.S. Federal, State, and local regulations or with regulations of Canada and its Provinces. This product, if unaltered by use, may be disposed of by treatment at a pemitted facility or as advised by your local hazardous waste regulatory authority. U.S. EPA WASTE NUMBER: DO02 (CharacteristidComsivity), applicable to wastes consisting only of this produd. 14. TRANSPORTATION INFORMATION THIS MATERIAL IS HAZARDOUS (Per 49 CFR 172.101) BY THE U.S. DEPARTMENT OF TRANSPORTATION. PROPER SHIPPING NAME: Corrosive liquids, n.0.s. (Zinc Chloride, Hydrochloric Acid) HAZARD CLASS NUMBER and DESCRIPTION: 8 (Corrosive) UN IDENTIFICATION NUMBER: UN 1760 PACKING GROUP: 111 W T LABEL@) REQUIRED: Corrosive (Class 8) NOTE: Consumer commodity shipments of this product I -gallon or less in volume may be renamed 'Consumer Commodity" and reclassed as ORM-D material. Refer to 49 CFR 173.154(c) for additional information. NORTH AMERICAN EMERGENCY RESPONSE GUIDEBOOK NUMBER (2000): 154 MARINE POLLUTANT: The components of this product are not designated by the Department of Transportation to be Marine Pollutants (49 CFR 172.101, Appendix B). TRANSPORT CANADA TRANSPORTATION OF DANGEROUS GOODS REGULATIONS: This material is considered as dangerous goods, per regulations of Transport Canada. Use the above information for the preparation of Canadian shipments. 15. REGULATORY INFORMATION ADDITIONAL U.S. REGULATIONS: U.S. SARA REPORTING REQUIREMENTS: The components of this product are subject to the reporting requirements of Sections 302,304, and 31 3 of T i e Ill of the Superfund Amendments and Reauthorization Act, as follows: Ammonium Chloride No Yes No Hydrochloric Acid No Yes Yes Methanol No yes Yes 1 Zinc Chloride No Yes Yes (as Zinc Compound) U.S. SARA THRESHOLD PLANNING QUANTITY: There are no specific Threshold Planning Quantities for the components of this product. The default Federal MSDS submission and inventory requirement filing threshold of 10,000 Ibs (4,540 kg) therefore applies, per 40 CFR 370.20. U.S. CERCLA REPORTABLE QUANTITY (RQ): Ammonium Chloride = 5000 Ib (2270 kg); Hydrochloric Acid = 5000 Ib (2270 kg); Methanol = 5000 Ib (2270 kg); Zinc Chloride = 1000 Ib (454 kg). U.S. TSCA INVENTORY STATUS: The components of this product are listed on the TSCA Inventory. 15. REGULATORY INFORMATION (Continued) STAY CLEAN@ LIQUID SOLDERING FLUX MSDS DATE: July 1,2004 PAGE 7 OF 9 <<>> ADDITIONAL U.S. REGULATIONS (continued): OTHER U.S. FEDERAL REGULATIONS: Not applicable. U.S. STATE REGULATORY INFORMATION: The components of this product are covered under specific State regulations, as denoted below: Alaska - Deslgnatod Toxic and H=rdous Minnesota - L i of Hazardous Substances: Pennsyhranla - Hazardous Substance List Substances: Ammonium Chloride Fume. Ammonium Chloride. Hydrochloric Acid, Ammonium Chloride, Hydmchloric Acid, Hydrochloric Acid. Melhanol, and Zinc Methanol, and Zinc Chloride Fume. Methanol, and Zinc Chloride. Chloride Fume. MlchlganClWcal Mabsriah Register: Zinc Rhode Island - Hazardous Subslance List Calbrnia - Permissibbe Exposure Limits for CMpouflds. Ammonium Chloride Fume, Hydrochloric Chemical Contaminants: Ammonium Missouri - Employer Informatlo~oxic Acid, Methanol, and Zinc Chloride Fume. Chloride, Hydrochloric Add, Methanol, and Substance List Ammonium Chloride. Texas - Hazardous Substance Lkt Zinc Chloride Fume. Hydrochloric Acid, Methanol, and Zinc Hydrochloric Acid, Methanol, and Zinc Florida - Substance Lkt: Ammonium Chloride. Chloride. Chloride Fume. Hydrochloric Aad, Methanol, and Zinc New Jersey - Right to Know Hatardoue West Virginia - Hazardous Substance L$t: Chloride Fume. Substance L i i Ammonium Chloride. Hydrochloric Aad. Methanol, and Zinc Illinois - Toxic Substance Li: Ammonium Hydrochloric Aoid, Methanol, and Zinc Chloride Fume. Chloride Vapor, Hydrochloric Acid, Melhand. Chloride. Wisconsin - Toxic and Hazardow and Zinc Chloride Fume. North Dakota - Uet of Haudous Chemicals, Substances: Hydrochlwic Acid, Methanol, Kansas - Section 3021j13 List: Hydrochloric Repoltable Quantifh: Ammonium and Zinc Chloride Fume. Aad, Methanol. Chloride, Hydrochlo~ic Atid, Methanol. and ~ c h u s e t t s - Substance List: Ammonium Zinc Chlonde. Chloride, Hydmchloric Add, Methanol, and Zinc Chloride Fume. CALIFORNIA SAFE DRINKING WATER AND TOXIC ENFORCEMENT ACT (PROPOSITION 65): No component of this product is on the California Proposition 65 Lists. ANSI LABELING (2129.1): DANGER1 CORROSIVE. MAY BE HARMFUL OR FATAL IF INHALED OR SWALLOWED. CAUSES SKIN OR EYE BURNS. Do not taste or swallow. Do not get on skin or in eyes. Avoid breathing vapors or mist. Keep container closed. Use only with adequate ventilation. Wash thoroughly after handling. Wear gloves, goggles, face- shields, suitable body protection, and NIOSH-approved respiratory protection, as appropriate. FIRSTAID: In case of contact, immediately flush skin or eyes with plenty of water for at least 15 minutes while removing contaminated clothing and shoes. If inhaled, remove to fresh air. If ingested, do not induce vomiting. Get medical attention. IN CASE OF FIRE: Use water fog, dry chemical, Con, or "alcohol" foam. IN CASE OF SPILL: Absorb spill with polypads or other suitable absohent materials. Neutralize with agent suitable for acids. Place residue in suitable container and seal. Consult Material Safety Data Sheet for additional information. ADDITIONAL CANADIAN REGULATIONS: CANADIAN DSUNDSL INVENTORY STATUS: The components of this produd are on the DSWDSL Lists. OTHER CANADIAN REGULATIONS: Not applicable. CANADIAN ENVIRONMENTAL PROTECTION ACT (CEPA) PRIORITIES SUBSTANCES LISTS: The components of this product are not on the CEPA Priorities Substances Lists CANADIAN WHMIS SYMBOLS: DIB: Poisonous and Infectious Materials1 Immediate and Serious Toxic Effects. E: Corrosive Material. 16. OTHER INFORMATION PREPARED BY: CHEMICAL SAFETY ASSOCIATES, Inc. 9163 Chesapeake Drive, San Diego, CA 92123-1 002 858/5650302 DATE OF PRINTING: July 13,2007 STAY CLEAN@ LIQUID SOLDERING FLUX MSDS DATE; July 1,2004 PAGE 8 OF 9 ## Provenance - Official: Yes - Source: - Source ID: `phmsa` - SHA-256: `26e4ccbe6418635e78e9d25e3e637c6a1ba045a3bd8fe3ff9868d4e106d786fc` - Retrieved: 2026-08-20T00:59:31.977Z - Exported: 2026-08-22T06:26:41.678Z - Document slug: `phmsa-interpretation-08-0294` ### Source metadata ```json { "materialSubtype": "interpretation", "interpretationArea": "hazardous_materials", "representation": "full_text_from_official_pdf", "companies": [ "The Law Offices of Michael A. Capuzzi" ], "individuals": [ "Mr. Michael A. 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