# H.B. Fuller Automotive Company — Hazardous Materials Safety Interpretation **Citation:** 98-0398 **Type / status:** guidance / guidance **Agency:** Pipeline and Hazardous Materials Safety Administration **Effective:** Not stated **Published:** 1998-04-15 98-0398 response to H.B. Fuller Automotive Company concerning 172.101. ## Document text <<>> Aman in U.S.Department of Transportation 400 Seventh Street, SW Washington, D.C. 20590 Research and special Programs Administration APR | 5 1998 Mr. Gene Secor Environmental Health and Safety Department H.B. Fuller Automotive Company 31601 Research Park Drive Madison Heights, MII 48071 Dear Mr. Secor: This is in response to your letters and telephone conversations with members of my staff and the Office of Hazardous Materials Technology asking if an adhesive with the proper shipping description "Self heating, solid, organic, n.o.s., 4.2, UN 3088," formulated as either PG II or PG Ill, is subject to the requirements specified in the Hazardous Materials Regulations (49 CFR Parts 171-180) when placed between automotive parts and offered for transportation on racks with no outside packaging. You stated the adhesive is applied to provide structural support to the parts before they are cured. You provided the following additional information: the parts are large metal assemblies such as rear tailgates, doors, hood decks, and fenders used predominantly on mini vans and small utility vehicles. 2. a maximum amount of 2.6 ounces of the adhesive is placed around the outer periphery of the parts in a 16-foot long continuous bead that is 3 mm wide and high, and the parts are sandwiched together. 3. the parts are cured in an oven at 300°F to 350°F. 4. the maximum temperature developed on the surface of the parts when they ! are cured is 300°F to 350°F. The answer is no, the adhesive no longer meets the definition of a Division 4.2 material in the packaging and transportation scenario described. Thank you for your inquiry. If we can assist you further, please contact us. Sincerely, Hathe a mitchell Hattie L. Mitchell, Chief Regulatory Review and Reinvention Office of Hazardous Materials Standards • <<>> Karim : • H.B. Fuller Automotive Company File: 172.101 • se: 300,410 31601 Research Park Drive (248)(870) 585-2200 • (800) 633-7789 Madison Heights, Michigan 48071 FAX (810) 585-3699 October 04, 1996 (scarch and Special Programs Administration Óffice of HazMat Standards 400 Seventh St., S.W. Washington D.C. 20590-0001 ATTN: Mr. Ed Mazzello We have many customers who purchase products regulated by DOT as follows: Self-heating, solid, organic, n.o.s., 4.2 UN3088, PG II (Contains epoxy resins) Self-heating, solid, organic, n.o.s., 4.2, UN3088, PG III (Contains epoxy resins) These materials are used in various automotive assemblies to provide structural strength after curing. Almost always the uncured material is sandwiched between metal pieces of the various assemblies while waiting to be cured. A customer has raised the following query: The regulated material is applied as described above but the assemblies are then shipped with uncured adhesives to another plant for finishing and curing. The amount of regulated material (adhesive) on these assemblies is small compared to a shipping container of this same adhesive. What is the regulatory status of the assemblies in transportation? My interpretation is that the assemblies are not regulated for transportation because the adhesive is a small part of the "whole" and the adhesive is not in a container. Your comments on these questions are appreciated. Regards, Heve cheer GENE SECOR Eastman Operations Coordinator <<>> JAN. - 23'98 (FRI) 15:37 HBF/API TEL: 810 5853699 JAN-16-1998 17:45 HMIC - P. 001 - P.01/01 FAX 1-23-98 Date 1/16/98 Number of pages including cover sheet до: Gone Secor wON: Eileen Edmonson H.B. Fuller Automotive Co. To: USDOT, Research and 31601 Research Park Dr. Special Programs Madison Heights, MI Administration 48071 DHM-12 400 7th Street, SW Phone (248) 585-2200 Washington, DC 20590- 0001 Fax Phone (248)585-3699 Phone cG: 202-366-8553 FaxPhone 202-366-3753 Filers-please see the attached 2 Ps. letter. REMARKS: Urgent For your review • Reply ASAP Please Comment Dear Mr, Secor: I presented your questions about how to test your adhesive as a Division 4.2 in the packaging your automotive manufacturing customers use, that is sandwiched between automotive parts as part of the metal curing process. One of our chemists, Dr. Charles Schultz, asked me to ask you the following questions. He said the information in the file you provided is not sufficient to information on: base an opinion as to whether these parts should be regulated. He said we need more detailed 1. What types of parts are involved? 2. How much adhesive is applied to the parts? 3. What is the curing temperature? 4. What is the maximum temperature developed on the surface of the parts when they are cured? If you wish to discuss these issues with Dr. Shultz directly, his telephone number is (202) 366- 4545. TOTAL P.B1 <<>> JAN. - 23'98 (FRI) 15:37 HBF/API TEL: 810 5853699 P. 002 " ... H.B. Fuller Automotive Company 31601 Research Park Drire (810) 585-2200 • (800) 633-7789 Madison Heights, Michigan 48071 FAX (810) 585-3699 January 23, 1998 Eileen Edmonson USDOT, RSPA DHM-12 400 7th St. S.W. Washington, D.C. 20590-0001 REFERENCE: Your Fax dated 1/16/98 Dear Ms. Edmonson: I have pursued the questions in the FAX with Dr. Charles Schultz as you suggested. A synopsis of our discussion follows: 1. What types of parts are involved? Answer: Large metal assemblies such as rear tailgates, doors, and mini vans and small utility vehicles. hood decks, and fenders used in the automobile industry -- - predominately on 2. How much adhesive is applied to the parts? Answer: Worse case, a maximum of 2.6 ounces of adhesives would be extruded around the periphery of a part and then sandwiched between overlapping metal sheets: Bead is 3mm wide and high by a maximum continuous length of 16 feet. Parts are then put in a rack to await fabrication. 3. What is the curing temperature? Answer: Actual parts with adhesive are cured in an oven at 300°F to 350°F. This generally occurs during; the cycle used to cure (dry) freshly applied paint. <<>> JAN. - 23'98 (FRI) 15:37 HBF/API TEL: 810 5853699 - P. 003 ... 4. What is the maximum temperature developed on the surface of the parts when they are cured? Answer: 300° to 350°F during the paint cure cycle. Although curing can take place very slowing at ambient temperatures, the large quantity of metal in an assembly dissipates heat as rapidly as it is formed so there is no noticeable surface temperature rise. Dr. Schultz and I are both in agreement that the situation described here and in my presides coresponded pes any hazard in reparation and the assembles would be Eileen, we would like to get this resolved; as always, we thank the Department for its help. Feel free to call me at (248) 583-1267 if there are any questions. Regards, deve decor ENE SECOR Environmental Health & Safety Department • Encl <<>> Re: H.B. Fuller Automotive Company letter of 10/4/96 concerning automotive parts containing uncured adhesive. The information in this file is not sufficent to base an opinion as to whether these parts should be regulated. We need more detailed information on: What types of parts are involved? How much adhesive is applied to the parts? What is the curing temperature? What is the maximum temperature developed on the surface of the parts when they are cured? EW-Schulk 1115198 <<>> TELEPHONIC CONVERSATION RECORD Specialist Placing Call: Eileen Edmonson ROUTING Date of Call: 1/13/98 SYMBOL INT Person (s) Contacted: Gene Secor, Eastman Operations Coordinator 31601 Research Park Drive, Madison Heights, MI Theix Organization: H.B. Fuller Automotive Company, 48071, (248) 585-2200 Date of Incoming Letter: 10/4/96 Specific Subject including section #'s and key "Self-heating, serinay used an adhesive to provide structura solid, organic, n.o.s., strength between auto parts prepared for curing be shipped as unregulated material? Summary: In a follow up conversation to a telephone message I'd ne is responsible for determining the hazard class of the material lett Mr. Secor, I explained that the Sciences Branch pointed out how now that it is exposed to the air and sandwiched between the metal auto parts. insufficient material present to meet the Division 4.2 hazard MI. Secor agreed and stated he believed there was class. in writing. However, he requested that I present him with that statement this type of testing was reviewed in the past by Charles Schultz and - spoke with Hattie Mitchell on the matter. She said asked me to present it to him for his opinion. Comments for Further Action: Discuss Division 4.2 testing with Charles Schultz. Present response to Hattie. Specialist Signature: Gile Adrondon Date: 1/13/98 <<>> TELEPHONIC CONVERSATION RECORD Specialist Placing Call: Eileen Edmonson ROUTING Date of Call: 12/10/97, 12/16/97 SYMBOL INT Coordinator Person (s) Contacted: Gene Secor, Eastman Operations 31601 Research Park Drive, Madison Heights, MI Inell Organization: H.B. Fuller Automotive Company, 48071, (248) 585-2200 Date of Incoming Letter: 10/4/96 Specific Subject (including section #'s and key words) : 4.2, UN 3088, PG II and PG III, (contains epoxy "Self-heating, solid, organic, n.o.s., resins) used an adhesive to provide structural shipped as unregulated material? strength between auto parts prepared fox curing be Summary: Mr. Secor is inquiring said his company sells the adhesive in 5 gallon pails and 55 gallon on behalf of his customers. He drums to car manufacturers, like Ford Co. sandwich the material approximately 0.015 - 1 inches thick between 2 He said these companies pieces of metal, like doors parts, etc. of material is used between parts. Mr. Secor said 1 ox 2 lbs transport these parts without packaging by motor vehicle over public The motor vehicle companies then highways to a facility with a curing oven. Mr. Secor said during knowledge, there have been no incidents because not enough of the air, but, to his material is present for the material to demonstrate its hazard. He suppressing the reaction of the material. also said the metal parts that surround the material aid in cure without being treated to the heat of a curing oven, but it He said the material can would take a long time. safety data sheet. On 12/16/97, he said he sent me the material I asked him to supply me with a material safety data sheet by facsimile on 12/12/97 for the PG II material, since it was the worst case, and the report on the classificatior test procedures performed on the material. Comments for Further Action: Supply DHM-21 with the material and determination that the material is unregulated when sandwiched incoming MI. Secor submitted and ask if they agree with his between metal auto parts. Specialist Signature: Elen 9. Carmin Date: 12/16/97 <<>> Naruta H.B. Fuller Automotive Company File: 172.101 • SC: 300,410 Madison Heights, Michigan 48071 31601 Research Park Drive (148)(870) 585-2200 • (800) 633-7789 FAX (810) 585-3699 October 04, 1996 You like me forespond? Lesearch and Special Programs Administration Eleen, Dith-iz . Office of HazMat Standards 400 Seventh St., S.W. x64481 Washington D.C. 20590-0001 ATTN: Mr. Ed Mazzello We have many customers who purchase products regulated by DOT as follows: Selt-heating, solid, organic, n.o.s., 4.2 UN3088, PG II (Contains epoxy resins) Self-heating, solid, organic, n.o.s., 4.2, UN3088, PG III (Contains epoxy resins) These materials are used in various automotive assemblies to provide structural strength after curing. Almost always the uncured material is sandwiched between metal pieces of the various assemblies while waiting to be cured. A customer has raised the following query: The regulated material is applied as described above but the assemblies are then shipped with uncured adhesives to another plant for finishing and curing. The amount of regulated material (adhesive) on these assemblies is small compared to a shipping container of this same adhesive. What is the regulatory status of the assemblies in transportation? My interpretation is that the assemblies are not regulated for transportation because the adhesive is a small part of the "whole" and the adhesive is not in a container. Your comments on these questions are appreciated LMTE 10: 18A 1/1/98EE Regards, Heve Neces - ENTERED GENE SECOR Eastman Operations Coordinator 12/23/97 ... <<>> Mane on the hit tape did walk on su. Secar payo the pheyeical state, t amount of this prateed his customer Do You Yaink he's right! Gilen x64481 whether the material Just the raw hegin mith incorpor material on ted in the paid as still 42 re component. something else e. Ke in op to the 12/24197 plipper to decide - They should terke the whole thing (pant?) into con- sideratin, not <<>> TELEPHONIC CONVERSATION RECORD Specialist Placing Call: Eileen Edmonson ROUTING Date Of Call: 12/10/97, 12/16/97 SYMBOL INT Coordinator Person (s) Contacted: Gene Secor, Eastman Operations Their Organization: H.B. Fuller Automotive Company, 31601 Research Park Drive, Madison Heights, MI 48071, (248) 585-2200 Date Of Incoming Letter: 10/4/96 Specific Subject (including section #'s and key words): Can "Self-heating, solid, organic, n.o.s., 4.2, UN 3088, PG II and PG III, (contains epoxy - in the mo resins) used an adhesive to provide structural strength between auto parts prepared for curing be shipped as unregulated material? Summary: Mr. Secor is inquiring on behalf of his customers. He sells the adhesive in 5 gallon pails and 55 gallon sandwich the material approximately 0.015 - 1 inches thick between 2 He said these companies pieces of metal, like doors parts, etc. Mr. Secor said 1 or 2 Ibs of material is used between parts. transport these parts without packaging by motor vehicle over public The motor vehicle companies then highways to a facility with a curing oven. Mr. Secor said during this stage the material is exposed to the air, but, to his material is present for the material to demonstrate its hazard. He knowledge, there have been no incidents because not enough of the also said the metal parts that surround the material aid in suppressing the reaction of the material. He said the material can cure without being treated to the heat of a curing oven, but it would take a long time. safety data sheet. On 12/16/97, he said he sent me the MATERIAL SAFETY DATA SHEET by facsimile on 12/12/97 for the PG II material, since it was the worst case, test procedures performed on and the report on the classification the material. Comments for Further Action: Supply DHM-21 with the material and determination that the material is unregulated when sandwiched incoming Mr. Secor submitted and ask if they agree with his between metal auto parts. Specialist Signature: Filen Enset Date: 12/16/97 : <<>> Ubb. -12 Y/IFK|/ 09:00 TBL:810 0809 - - P. 001 H.B. Fuller Automolive Company 31601 Research Park Drive Madison Heights, Michigan 48071 (810) 595-2200 - (800) 633-7789 FAX (810) 585-3699 MAIN FAX NUMBER: SALES DEPT. FAX NUMBER: (50) 585-3699 ORDER ENTRY DEPT. FAX NUMBER: (810) 585-4897 (810) 585-3799 FACSIMILE COVER SHEET TO: EILEEN ED MONSON COMPANY: US DOT FAX NUMBER: 202 3663753 FROM: GENE SECOR PHONE NUMBER: (878) 2485831267 DATE: 12-12-97 URGENT FOR YOUR REVIEW REPLY ASAP AS REQUESTEDA PLEASE COMMENT O FYI PAGES INCLUDING THIS COVER SHEET: 13 MESSAGE Pei: our discusson, Attacked ie HiDs for PErI Mat'l (WorsT cue), Test Report, cal cops & my kelter to DoT leith a ddi tonal comments clan fying end use. Call us it: any questioni Thanks. GeneSeco <<>> DEG. -12 9/(FKI/ 09:00 HBP/ API TBL: 810 0853699 P. 002 H.B. Fuller Automotive Company 31601 Research Park Drive Madison Heights, Michigar 48071 FAX (810) 595-3699 (810) 585-2200 - (800) 633-7789 October 04, 1996 USDOT Research and Special Prograns Administration Office of HazMat Standards 400 Seventh St., S.W. Washington D.C. 20590-0001 Sold by fulle in 5-gal Pails and 55-gal drums ATIN: Mr. Ed Mazzello We have many customers who purchase products regulated by DOT as follows: Self-heating, solid, organic, n.o.s., 4.2 UN3088, PG II (Contains epoxy resins) Self-heating, solid, organic, 1. o.s., 4.2, UN3088, PG III (Contains epoxy resins) ! These materials are used in various automotive assemblies to provide structural strength the various assemblies while waiting to be cured. after curing. Almost always the uncured material is sandwiched between metal pieces of A customer has raised the following query: The regulated material is applied as described above but the assemblies are then shipped with uncured adhesives to another plant for finishing and curing. The amount of regulated material (adhesive) on these assemblies is small compared to a shipping container of this same adhesive. What is the regulatory status of the assemblies in transportation? My interpretation is that the assemblies are not regulated for transportation because the adhesive is a small part of the "whole" and the adhesive is not in a container. Your comments on these questions are appreciated. Regards, Produet is Then skived or pungel from pails or drans dg our eus Jowers Hewe beer and sandwichel le tucen metal as alone. GENE SECOR Eastman Operations Coordinator Here Secer <<>> ubb. -12 Y/|HKI) VY:0U (5:810089Y ...... P. U03 -.... Creamery Commercial Park Dusilech in. U.S. Highway 206 & At. 15 Box 222 Augusta, NJ 07822 201-579-3188 ....... STUDIES FOR CLASSIFICATION • SELE-HEATING SUBSTANCES • LTWO LABORATORY SAMPLES) DTI Report 2539 - to - H.B. Fuller Automotive Products, Inc. Madison Heights, Michigan ! June 8, 1995 William J. Cryice, M.S., FAIC consulting Chemist <<>> 1BL:810 080J0YY i: r. 004 DI Report 2539 H.B. Fuller Automotive Products, Inc. I. INTRODUCTION • This report summarizes the results of a series of experiments performed by Dust Tech, Inc., Augusta, New Jersey, for H.B. Fuller Automotive Products, Inc., of Madison Heights, Michigan, under Purchase Order No. F18517. Contact with H.B. Fuller Automotive Products, Inc., was maintained through Mr. ene Seacore. Self-heating evaluations of two samples were conducted using the UN Test Method (14.3.4) to determine UN packaging class (4.2). IL. MATERIALS Two samples were submitted, which were tested as received. These were identified as "WC2290B" and "WC2390", epoxy adhesives; WC2290B was blue, and WC2390 was gray-green. III. DESCRIPTION OF EXPERIMENTS UN Test Method for-Self-Heating Substance The principle of the method (14.3.4) is to keep samples in stainless-steel screen cubes at constant temperature for 24 hours, making observations as to whether the temperature of the sample exceeds 200°C. (This test method is a godification of the Bowes-Cameron cage test, a self-heating test method for carbon.) The test procedure is performed in a hot air circulating-type oven (Blue M) with an inner volume of 12-15 liters, capable of controlling the internal temperature at 140°C * 2°C. Cubic sample containers with 2.5-cm and 10-cm sides, made of 0.15" : stainless-steel wire screening with a mesh opening of 0.53 mm (28 mesh), -1- <<>> P. OUS -.. DTI Report 2539 H.B. Fuller Automotive Products, Inc. with the top surface open, are used. Each container is housed in a cubic container cover made from 0:4-mm stainless-steel wire screen with a mesh • opening of 0.595 mm (26 mesh) and slightly Targer than the sample container, so that the container fits in this cover. In order to avoid the effect of air circulation, another stainless-steel cage, made from D.4-mm wire screen with a mesh opening of 0.595 mn (26 mesh) and 15 cm x 15 cm x 25 cm in size, is further installed to house the covered sample container. Stainless-stee1-sheathed thermocouples of 1/8" diameter are used for temperature measurement. One is placed in the center of the sample and : another between the sample container and the oven wall. The temperatures are measured continuous y. The sample powder or granulate (in the commercial form), is filled to the brim of the sample container, and the container tapped several times. If the sample settles, more is added. If the sample is heaped, it is leveled to the brim. The container is housed in the cover and hung at the center of the oven. : The oven temperature is raised to 140°C and kept there for 24 hours. The temperature of the sample is recorded. 1 The first test is conducted with the 10-cm cube sample. Observations are made to determine 1f spontaneous ignition occurs or if the temperature : of the sample exceeds 200°C. If negative results are obtained, no further testing is necessary. If positive results are obtained, a second test is conducted with a 2.5-cm cube sampie to determine the data for packing group assignment. • - 2- <<>> HBr/API TEL: 810 5833699 P. 006 - DI Report 2539 H.B. Fuller Automotive Products, Inc. IV. RESULTS OF EXPERIMENTS WC2390 (Gray-Green Paste) Positive in 10.0-cm cube Sample thermocouple read 10°C to 35 at 49 minutes, 100°C at 50 minutes, 150°C at 51 minutes, 200°C at minutes, rose slowly to 20°C at 43 minutes, rose quickly to 50°C 53 minutes, and crested at 215°C at about 70 minutes. Positive in 2.5-cm cube Sample thermocouple read 10°C at start, .. 30°C at 4 minutes, 55°C at 8 minutes, 75°C at 11 minutes, 85°C at minutes. 12 minutes, 200°C at 13 minutes, crested at 220°C at about 14 WC2290B (Blue Paste) Positive 1n 10.b-ca cube sample thermocouple read 12°C at start, ' at So minutes, les at minutes, minutes, at at minut minutes, t 100 at s, 310° a4 44°C at 40 minutes, 65°C at 60 minutes, 80°C minutes. 80 minutes, 210°C at 88 minutes, crested at 214°C at about 101 Negative in 2.5-cm cube Sample thermocouple read 12°C at start, 35°C at 4 minutes, 63°C at 8 minutes, 82°C at 12 minutes, 95°C at 193°C at about 27 minutes. 16 minutes, 104°C at 20 minutes, 128°C at 24 minutes, crested at DISCUSSION Sample WC2390 yielded temperatures in excess of 200°C in both 10.0-cm and 2.5-cm cube configurations. Sample WC2290B. yielded temperatures in excess of 200°C in the 10.0-cm cube but not in the 2.5-cm cube configuration. VI. SUBSTANCE CLASSIFICATION A substance should te classified in Division 4.2 if, in the first test using the 10-cm cube sample, spontaneous ignition occurs, or the temperature of the sample exceeds 200°C during the 24-hour testing time. Packing groups are assigned as follows: (a) Packing Group II is assigned to substances which give positive results when tested with the 2.5-cm cube sample. : • • - 3- <<>> ubk. "1 Y/IFKI) VY:U2 HBt /API - TEL: 810 5853699 __- P. 007 use report 255y - H.B. Fuller Automotive Products, Inc. (b) Packing Group III is assigned to substances which give positive 7.. results when tested with the 10-cm cube sample, but which give a negative result with a 2.5-cm cube sample. : Using these criteria, Sample WC2390 is considered Div. 4.2., Packing Group II. Sample WC22908 is considered Div. 4.2, Packing Group III. : é. <<>> ubb. -12 y/(rK1) 09:02 HBr /AP! TEL:810 5853699 " • -- P. 008 WC-2390 - Date Printed: 12/11/97 Page 1 of 6 MATERIAL SAFETY DATA SHEET SECIION 1: CHEMICAL PRODUCI AND COMPANY IDENTIFICATION COMPANY INFORMATION MSDS INFORMATION EFTEC NoIth America, I.I.C. 31601 Research Park Drive Preparation Date: 04/29/97 Madison Heights, MI 48071 Supersedes: 09/27/96 Phone: 800-633-7789 Prepared By: Industrial Hygiene Fax: 810-585-3699 Phone Number: 612-236-5842 Ixansport Emergency Phone Number Medical Emergency Phone Number: 1-800-228-5635 ext 018 (CHEMTREC): 1-800-424-9300 PRODUCT INFORMATION Product Name/Number: WC-2390 Product Description (product use): Epoxy resin SECTION 2: COMPOSITION/INFORMATION ON INGREDIENTS This Material Safety Data Sheet is prepared to comply with the United States Occupational Satety and Health Administration (OSHA) Hazard Communication Standard (29 CFR 1910.1200) and the Canadian Workplace Hazardous Materials Information System (WHMIS). Unlisted ingredients WHMIS ingredient disclosure list. are not 'hazardous' per the OSHA standard and/or are not found on the Chemical/CAS Number Percent OSHA PEL ACGIH TIV Epoxy resin 50-70% Not estab. Not estab. Polyamide resin 10-30% Not estab. Not estab. Epoxy-amine adduct 1-5% Not estab. Not estab. Calcium oxide (1305-73-8) LD50: No data found LC50: No data found 5-10% 5 mg/M3 2 mg/M3 See Section 16 for additional information. SECTION 3: HAZARDS IDENTIFICATION EMERGENCY OVERVIEW Potential skin sensitizer • POTENTIAL HEALTH EFFECTS Eyes: Eye contact with liquid product will cause irritation. Skin: Epoxy resins are potential skin sensitizers. : <<>> (Eb:810 0853699 P. 009 WC-2390 - Date Printed: 12/11/97 Page 2 of 6 Inhalation: Inhalation is not an anticipated route of exposure. Ingestion: Harmful if swallowed. Chronic: No anticipated chronic effects. REGULATED CARCINOGEN STATUS: Manor ost 118 ed carcinon negulated levels of NED, TARC, Existing er 1th essestions Affected by Exposure: No known effects on SECTION 4: FIRSI AID MEASURES If in eye: Flush immediately with water for 15 minutes. Consult a physician if irritation persists. If on skin: Wash affected area with soap and water. Launder contaminated clothing before reuse. If ingested: If person can swallow, give one glass of water or milk. Do not induce vomiting. Never give anything by mouth to an unconscious person. Get immediate medical attention. 1 SECTION 5: FIRE FIGHTING MEASURES Flash Point/Method: 300+ degrees F Pensky-Martens ... Upper Explosive Limit/Lower Explosive Limit: Not applicable Autoignition Temperature: Not applicable Appropriate Extinguishers: Use water spray, foam, dry chemical or carbon dioxide. Special Fire Fighting Procedures: Persons exposed to products of combustion should wear self-contained breathing apparatus and full protective equipment. Unusual Fire and Explosion Hazards: None known. Hazardous Combustion Product: Incomplete combustion can yiela low molecular weight: hydrocarbons, carbon monoxide, nitrogen compounds SECTION 6: ACCIDENTAL RELEASE MEASURES Spill or Leak Procedures: Wear rubber gloves and wipe up with absorbent material. Residue may be removed with a chlorinated solvent. • • <<>> ub. 12 9/INKI) 09:02 HBr/AP! TEL: 810 5853699 - P.010 WC-2390 Date Printed: 12/11/97 Page 3 Of 6 SECTION 7: HANDLING AND STORAGE 1 HANDLING INFORMATION 1 Avoid skin contact with product at all times. STORAGE INFORMATION consult the Technical Data Sheet for specific storage instructions. SECTION 8: EXPOSURE CONTROLS/PERSONAL, PROTECIION Eye Protection: Safety glasses. Skin Protection: Prevent contact by using rubber gloves and clothing before Ieuse. appropriate protective clothing. Launder contaminated Respiratory Protection: Not normally required. Use NIOSH/MSHA approved respirator if conditions warrant. Ventilation: General dilution ventilation. SECTION 9: PHYSICAL AND CHEMICAL PROPERTIES Color: Physical State: Paste Odor: Green odor Threshold: Mild • (Ethereal) Weight per Gallon: Not established •. • Specific Gravity: 11.3 Ibs. * Solids by weight: 1.36 PH: 99.5 Boiling Range: Not applicable Freezing/Melting Point: Not established Vapor Pressure: Not established Not established : Vapor Density: Evaporation Rate: Not established Not established water/Oil Partition Coefficient: Not established SECTION 10: STABILITY AND REACTIVITY DATA Stability: Stable Incompatibility: Not established Hazardous Decomposition: Nitrogen compounds ! : Hazardous Polymerization: Will not occur <<>> ПОГ/АГІ - P.011 WC-2390 Date Printed: 12/11/97 Page 4 Of 6 ! SECTION 11: TOXICOLOGICAL INFORMATION No data available • •. SBCTION 12: ECOLOGICAL INFORMATION No data available SECTION 13: DISPOSAL CONSIDERATIONS o tne best of our knowledge, this product does not meet the Regulations 40 CFR 261. lefinition of hazardous waste under the U.S. EPA Hazardous Waste landfill. Consult state, local or provincial authorities for more Solidify and dispose of in an approved restrictive requirements. SECTION 14: TRANSPORTATION INFORMATION UNITED STATES DEPARTMENT OF TRANSPORTATION (DOT) DOT Proper Shipping Name: (Epoxy Resin) Self-heating Solid, Organic N.O.S. DOT Label: DOT Hazard Class/I.D. Code: 4.2, UN3088 DOT Packaging Group: Spontaneously Combustible It is our opinion that the information provided here may be used to Dangerous Goods. transport this product in compliance with Canadian Iransportation of INTERNATIONAL TRANSPORTATION IATA Proper Shipping Name: Self-Heating Solid, Organic, N.O.S. IATA Hazard Class: 4.2 (Epoxy Resin) IATA I.D. Code: IATA Label: UN3088 IATA Packaging Group: Spontaneously Combustible SECTION 15: REGULATORY INFORMATION FEDERAL Toxic Substances Control Act (TSCA) Section 4 - Test Rule is (are) subject to a Section 4 Test Rule: This product contains the following chemical substance (s) that • ... <<>> НВГ/ API [bb 810 8599 P. 012 WC-2390 Date Printed: 12/11/97 Page 5 of 6 Section 8 (b) - Inyentory Status 1. This product is in compliance with the Ioxic Substances Control Act's Inventory requirements. Section 12 (b) - Export Notice Requirements This product contains a chemical substance that is currently on the EPA's Section 12(b) Export List. Within seven days of entering into a contract to export and certainly no later EPA of their intent. export, the agent of export must notify the Contact the H.B. Fuller TSCA Compliance Manager at 612/481-4816 fOI the identity of the Section 12(b) chemical (s). SARA TITLE III 1 Section 313: This product does not contain regulated levels of requirements of section 313 of Title III of the any toxic chemical subject to the reporting Superfund Amendments and Reauthorization Act of 1986 STATE REGULATIONS (SARA) and 40 CFR paxt 372. California Proposition 65: Proposition 65, Ihe Safe Drinking Water 4 and Ioxic Enforcement Act of 1986: California to cause cancer (C) This product contains chemical (s) known to the state of ... or reproductive (x) damage. 14808-60-7 106-89-8 WHMIS IDENTIFICATION/OTHER INTERNATIONAL REGULATIONS D2B, B6 -.. <<>> ubb. 12 y/rKI/ v9:00 HBr/AP 1 TEL: 810 5853699 1. 013 WC-2390 Date Printed: 12/11/97 Page 6 Of 6 SECTION 16: ADDITIONAL INFORMATION This product contains the following substance(s) identified by OShA, WINIS, or the ACGIH as hazardous. During normal use, the material will not present an exposure risk. final state and is abraded or disturbed, dusting and exposure may Once the product has reached its 10-30% Calcium carbonate (1317-65-3) Exposure limit respirable dust 5 mg/M3 (OSHA) Exposure Limit total dust 15 mg/M3 (OSHA) 10 mg/M3 (ACGIH) LD50: No data fourd LC50: No data found 6.0% laic-containing no asbestos fibers (14807-96-6) Expose Int total dust 15 mg/M3 (OSHA) 10 mg/M3 (ACGIH) LD50: No data found LC50: No data found Exposure limit restirable dust 2 mg/M3 (OSHA) 2 mg/M3 (ACGIH) HMIS RATING Health-2 Flammability-1 Reactivity-1 protective equipment recommendations. See SECTION 8: EXPOSURE CONTROLS/PERSONAL PROTECTION for personal The information and recommendations set forth herein are believed to be accurate. Because some of the information is derived from information provided to the #.B. Fuller Company from its suppliers, and because the regarding the accurag te dea or the points To Be beathed Send : <<>> H.B. Fuller Automotive Company ( 31601 Research Park Drive Madison Heights, Michigan 48071 Ü7 OCT : FIREL TAK MI 480/483 DI 1:98/ RESEARCH AND SPECIAL PROGRAMS ADMINISTRA USDOT OFFICE OF HAZMAT STANDARDS 400 SEVENTH ST. WASHINGTON D.C. 20590-0001 ATTN : ED MAZZELLO ------ -- ## Provenance - Official: Yes - Source: - Source ID: `phmsa` - SHA-256: `8d1aa474ca6f0702677a05d2de65df0e91912fdaf086cda13f24fe9109ea42f8` - Retrieved: 2026-08-20T00:59:31.977Z - Exported: 2026-08-23T17:29:50.381Z - Document slug: `phmsa-interpretation-98-0398` ### Source metadata ```json { "materialSubtype": "interpretation", "interpretationArea": "hazardous_materials", "representation": "full_text_from_official_pdf", "companies": [ "H.B. 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