# Myers Industries — Hazardous Materials Safety Interpretation **Citation:** 98-0403 **Type / status:** guidance / guidance **Agency:** Pipeline and Hazardous Materials Safety Administration **Effective:** Not stated **Published:** 1993-05-01 98-0403 response to Myers Industries concerning 172.101. ## Document text <<>> • of Transportation U.S. Department Washinglon, D.C. 400 Seventh Street. S.W 20590 Research and Administration Special Programs MAY - | 1993 Ms. Barb Germano Myers Industries 1293 S Main Street Akron, OH 44301 Dear Ms. Germano: This is in response to your letter regarding the classification of an aerosol containing carbon dioxide and trichloroethylene in 16 ounce cans for shipment by vessel in accordance with the International Maritime Dangerous Goods (IMDG) Code. You asked if you are correct in classifying and describing the material as an "Aerosol". I apologize for the delay in responding and hope it has not caused any inconvenience. Under 49 CFR 173.22, it is the shipper's responsibility to properly classify a hazardous material. This office does not perform that function. Based on the information you provided on the Material Safety Data Sheet enclosed with your letter, it is the opinion of this Office that your material is an "Aerosol, Division 2.2" (nonflammable gas). Under the HMR, aerosols must comply with the requirements in 49 CFR 173.306(a)(3). The following description applies: "Aerosols, 2.2, UN 1950, Limited Quantity" Under the HIMR, with certain exceptions, if all or part of the transportation is by vessel, a hazardous material Which is classed, packaged, marked, labeled, placarded and described in accordance with the requirements of the IMDG Code may be offered and accepted, and transported in the United States (see 49 CFR 171.12(b)). The IMDG Code permits aerosols with a capacity not exceeding 1000 ml to be transported in accordance with the limited quantity provisions in Section 18 of the General Introduction of the IMDG Code. In that case, the following description and marking is appropriate: "Aerosols, Class 2, UN 1950, Limited Quantity" For 1000 ml or less, package may be marked "AEROSOLS" (Instead of Non-flammable (Gas label) You may wish to consult Section 18 of the IMDG Code for further information on excepted documentation on package marking. : • <<>> For your information, in a final rule published in the Federal Register under Docket HM- 215B [62 FR 24690; 05/06/97], in 49 CFR 171.8, the term "Aerosol" was defined. Aerosol means any non-refillable metal receptacle containing a gas compressed, liquefied, or dissolved under pressure, the sole purpose of which is to expel a nonpoisonous (other than a Division 6.1 Packing Group III material) liquid, paste, or powder and fitted with a self-closing release device allowing the contents to be ejected by the gas. I hope this information is helpful. If I can be of further assistance, please contact us. When Hilling Delmer F. Billings Chief, Standards Development Office of Hazardous Materials Standards <<>> YOU' 6 '97 16:03 FROM FINANCE-DEPT TO 12023668700 PAGE. 001 • Engum File! 22101(a) S0.412,423 Myers Industries 1293 S Main St Akron, OH 44301 Fax Cover Sheet : DATE: November 6, 1997 TO: Helen Engrum PHONE: U.S. D.O.T. FAX: 202-366-8700 FROM: Barb Germano PHONE: 330-253-5592 Myers Industries FAX: 330-761-6156 RE: International Shipments We are trying to ship (internationally) 16 ounce acrosol cans containing Trichloroethylene. Using IMDG regulations, this product is considered an Aerosol, Class 2, UN 1950. The IMDG Book states that no label, other than the marking "Aerosols" is necessary for quantities of less than 1000 cm3 (quart). labeled "Stow Away From Foodstuffs". The trucking company we are using has called and said that this must be If I am correct about the Proper Shipping Name being Acrosols, are we allowed to follow the IMDG page and mark the carton as Aerosols? I also sending a copy of the MSDS and the IMDG page. Would you please answer in writing. Thank you • <<>> NOV, 12 ' 97 12:48 FROM FINANCE-DEPT TO 12023663753 PAGE. 001 : Myers Industries 1293 S Main St • Akron, OH 44301 • Fax Cover Sheet DATE: November 6, 1997 IO: Helen Engrum PHONE: 02-366-4473 U.S. D.O.T. FAX: 202-366-8700 FROM: Barb Germano Myers Industries PHONE: 330-253-5592 FAX: 330-761-6156 RE: International Shipments We are trying to ship (internationally) 16 ounce aerosol cans containing Trichloroethylene. Using IMIG regulations, this product is considered an Aerosol, Class 2, UN 1950. The IMIDG Book states that no label, other than the marking "Aerosols" is necessary for quantities of less than 1000 cm3 (quart). The trucking company we are using has called and said that this must be labeled "Stow Away From Foodstuffs". If I am correct about the Proper Shipping Name being Aerosols, are we allowed to follow the IMDG page and mark the carton as Aerosols? I also sending a copy of the MSDS and the IMDG page. Would you please answer in writing. Thank you • • <<>> NOV 12 ' 97 12:48 FROM FINANCE-DEPT ТО 12023663753 PAGE. 002 # win tond Post-it® Fax Note 7671 Date HELEN From ag95 Co/Dept, Co. Phone * Phone# Fax # Fax $ ... • AEROSOLS DA DO ON NO 1950 • Formula Explosive limits Properties MARINE POLLUTANT •:: in the General Index to this Code. identified with "P" or 1% or more of substance(s) identified with "PP" Applicable ony to products containing 10% or more of substance(s) D'AEROSOLS" meaning aerosol dispensers are any non-refillable receptacles meeting the requirements of parsgraph 8.9 of Annex 1, ... ....liquefied or dissolved under pressure with or without a liquid, paste or.. made of metal, glass or plastles and containing a gas compressed, powder, and fitted with a release dovice allowing the contents to be paste or powder or in a liquid state or in a gaseous state. ejected as solid or liquid particles in suspension in a gas. sa a foam, Observations which they are filled. The Daerosois & should comply with the provisions of the country in DACCORDING TO PROPERTIES Label They should be provided with protection against inadvertent discharge. They should be of a type which shows no visible leakage D Sor loss However, tor aerosols with a of contents of more than 1% in mass & (or 1 gram if the total contents the mark "AEROSOLS" capacity of 1000 cm or less lemperature may be reduced to 45°C for carriage solely within are less than 100 grams) J when stored for 18 hours at 55°C. This of a labels may be applied inslead •A Isbel of class 2.1 applies if the contents include more than 45%. temperate climates (i.e. in latitudes greater than 30" North or South). components are gases which are flammable in air at normal pressure by mass, or more than 250g of flammable components. Flammable (for marine pollutants only) MARINE POLLUTANT mark less than or equal to 100°C. or substances or preparations in liquid form which have a flashpoint The provisions of this Code should not apply to asrosols with a The provisions of this Code should not apply to aerosols with a capacity of less than 50 cm°. ! - no flammable gas present, - internal pressure not greater than 8,4 kg/cm* gauge at 55°C, ' capacity of 1000 em? or less when she following conditions are mst: igt or less - less than 10% by mass of the total contents consisting of - less than 1% by mass of toxic substances present in liquid flammable liquid, - less than 0.2% by mass of corrosive substances present in the concentrate, 1080 ст з liquid concentrate. y IMDG CODE - PAGE 2102 (first of two pages, Amdt. 23-96 <<>> NOU 12 ' 9? 12:49 FROM FINANCE-DEPT TO 12023553753 PAGE. 083 update MSDS NO: 0112 PATCH RUBBER COMPANY MATERIAL SAFETY DATA SHEET Product Name: Product Code No.: 16-481 CLEANER FLUID, AEROSOL (Non-Flammable) Page: Issue Date: 1/9/96 1 of 7 MANUFACTURER: Call CHEMTREC only in the event of chemical P.O. BOX H PATCH RUBBER COMPANY exposure, or accident involving chemicals. emergencies involving a spill, leak, fire, ROANOKE RAPIDS, N.C. 27870 (800) 424-9300 Cont. USA (202) 483-7616 (Collect) Alaska & Hawai TELEPHONE: (919) 536-2574 Call LOS ANGELES Poison Information Center HEALTH EMERGENCIES: (24 hrs.) 1-800-356-3129 PRODUCT IDENTIFICATION CLEANER FLUID (Non-Flammable) 16-481 •.. ~ DOT PROPER SHIPPING NAME: • ID NUMBER: Consumer Commodity DOT HAZARD CLASSIFICATION: ORM-D SECTION I - HAZARDOUS COMPONENTS Components/Percent/Exposure Limits/Units/Agency/Type • Trichloroethylene 90-100% 79-01-6 (Stabilized) See Section 3 Carbon Dioxide 1-10% 124-38-9 OSHA PEL 10,000 ppm ACGIH TV 5,000 ppm • ACGIH STEL 30,000 ppm : • <<>> NOU 12 '97 12:49 FROM FINANCE-DEPT TO 12023553753 PAGE. 004 •. Product Name: Product Code No.: 16-481 CLEANER FLUID, AEROSOL (Non-Flammable) Page: Issue Date: 1/9/96, 20f7 SECTION II - EMERGENCY & FIRST AID PROCEDURES *.. EMERGENCYA. Have a physician call Los Angeles POISON INFORMATION CENTER (24 hrs.) 1-800-356-3129 INHALATION: Remove to fresh air. If not breathing, give artificial respiration, preferably mouth-to-mouth. if breathing is difficult, give oxygen. Call a physician. EYE OR SKIN CONTACT: Flush eyes and skin with plenty of water (soap and water for skin) for a least 15 minutes while removing contaminated clothing and shoes. If imitation occurs, consult a physician. Thoroughly clean contaminated clothing and shoes before reuse or discard. INGESTION: If conscious: Drink large quantities of water. DO NOT induce vomiting. Take immediately to a hospital or physician. If unconscious: or in convulsions, fake immediately to a hospital. DO NOT attempt to give anything by mouth to an unconscious person. NOTES TO PHYSICIAN (INCLUDING ANTIDOTES): Never administer adrenaline following Trichloroethylene Trichloroethylene. overexposure. Increased sensitivity of the heart 1o adrenaline may be caused by overexposure to • .. 'SECTION III - HEALTH HAZARDS/ROUTES OF ENTRY HEALTH HAZARD DATA TOXICITY DATA: LC 50 Dermal: LC 50 inhalation: LCLO(RATS) 8000 PPM/4 Hour LD 50 Ingestion: Skin/Eye Irritation: Not Determined See Section 2 Fish, LC50 (Lethal Concentration): See Section 3 (Rat) 4900-7000 Mg/Kg • CLASSIFICATION: (POISON, IRRITANT, ETC.) Inhalation: Skin/Eye: Skin: Slightly Toxic Not Determined Ingestion: Skin-Mildly Iritating/Eye Imitant Aquatic: See Section 3 Slightly to Moderately Toxic TOXICITY DATA - AQUATIC DATA: Mysid Shrimp - 96 Hour LC 50 - 14 MG/L - Slightly Toxic Sheepshead Minnows - 98-Hour LC50 - 52 MG/L - Slightly Toxic Marine Alga - 96 Hour EC 50 - 95 MG/L - Slightly Toxic <<>> NOU 12 '97 12:50 FROM FINANCE-DEPT TO 12023563753 PAGE.005 ... • = .:. ... Product Name: Product Code No.: 16-481 CLEANER FLUID, AEROSOL (Non-Flammable) Page: Issue Date: 1/9/96 30f7 SECTION III - HEALTH HAZARDS/ROUTES OF ENTRY (continued) ingestion and other types of overexposure information in the order of the most hazardous and the most likely EFFECTS OF OVEREXPOSURE: This section covers effects of overexposure for inhalation, eye/skin contact, route of overexposure. IS CHEMICAL LISTED AS A CARCINOGEN OR POTENTIAL CARCINOGEN? NTP - No LARC - No OSHA - No MEDICAL CONDITIONS GENERALLY AGGRAVATED BY EXPOSURE: None known. PERMISSIBLE EXPOSURE LIMITS: OSHA: 100 PPM, 8-Hour TWA (Time Weighted Average). • 300 PM, Acceptable maximum peak above the ceiling concentration for an 8 hour 200 PM, Acceptable Ceiling Concentration. (29 CFR 1910.1000, Table Z.2). shift. The maximum duration for this exposure is 5 minutes in any 2 hours ACGIH: 50 PPM. 8-Hour TWA (Time Weighted Average). 200 PPM, STEL (Short-Term Exposure Limit). ACUTE: INHALATION: Trichloroethylene is a central nervous system depressant which can cause irritation of the system damage, unconsciousness and death in confined or poorly ventilated areas. Fatalities following severe respiratory tract, dizziness, nausea, headache, loss of coordination and equilibrium, possible central nervous acute exposure have been attributed to ventricular fibrillation resulting in cardiac failures. EYES/SKIN: Liquid splashed in the eye can result in discomfort, pain and imitation. Prolonged or repeated becoming trapped against the skin by contaminated clothing and shoes, and skin absorption can occur. contact with liquid on the skin can cause imitation and dermatitis. The problem may be accentuated by liquid as listed above for inhalation. Vomiting and subsequent aspiration into the lungs may lead to chemical pneumonia INGESTION: Swallowing of this material may result in irritation of the mouth and Gl tract along with other effects and pulmonary edema which is a potentially fatal condition. CHRONIC: Prolonged exposure above the OSHA permissible limits may result in liver and kidney damage. : tumors were induced in mice, there is no evidence that Trichloroethylene poses a carcinogenic risk to humans. Trichloroethylene has been extensively studies for chronic effects in animals. While there are studies in which -.Tnchloroethylene is listed in Group 3 by IARC and is not listed by NTP or OSHA. <<>> NOV 12 : '97 12:50 FROM FINANCE-DEPT TO 12023663753 PAGE. Ø05 Product Name: Product Code No.: 16-481 CLEANER FLUID, AEROSOL (Non-Flammable) Page: Issue Date: 1/9/96 4 of 7 • SECTION IV - SPECIAL PROTECTION INFORMATION respirator when concentrations exceed the permissible limits. Use self-contained breathing apparatus (SCBA) or RESPIRATORY PROTECTION: Use a half or full face piece organic vapor chemical cartridge or canister full face piece airline respirator with auxiliary SCBA operated in the pressure-demand mode for emergencies and for all work performed in storage vessels, poorly ventilated rooms, and other confined areas. Respirators must be be observed. Respirator protection programs must be in accordance with 29 CFR 1910.134. approved by NIOSH/MSHA. The respirator use limitations made by NIOSH/MSHA and by the manufacturer must VENTILATION (TYPE): Use local exhaust or dilution ventilation as appropriate to control exposures to below permissible limits. EYE PROTECTION: Splash proof goggles. GLOVES: Viton (R), Silver Shield (R), Polyvinyl Alcohol (Degrades in Water). prevent skin contact. Personal protective clothing and use of equipment must be in accordance with 29 CFR OTHER PROTECTIVE EQUIPMENT: Boots, aprons, or chemical suits should be used when necessary to 1910.132 and 29 CFR 1910.133. ¡SECTION V - REACTIVITY DATA -_ STABILITY: Stable Conditions to Avoid: Avoid open flames, hot glowing surfaces or electric arcs. HAZARDOUS POLYMERIZATION: Will not occur. Conditions to Avoid: None INCOMPATIBILITY (MATERIALS TO AVOID): Avoid contamination with Caustic Soda, Caustic Potash or oxidizing materials. Shock sensitive compounds may be formed. HAZARDOUS DECOMPOSITION PRODUCTS: Hydrogen Chloride and possible traces of Phosgene. SECTION VI - SPILL OR LEAK PROCEDURES "*HIGHWAY /RAILWAY SPILLS" Call CHEMTREC (1-800-424-9300) Cont. U.S. (Collect) (202-483-7616) from Alaska & Hawaii STEPS TO BE TAKEN IF MATERIAL IS SPILLED OR RELEASED: Immediately evacuate the area and provide respiratory and skin/eye protection (See Section 4) should be permitted in area. Dike area to contain spill. Take maximum ventilation. Unprotected personnel should move upwind of spill. Only personnel equipped with proper precautions as necessary to prevent contamination of ground and surface waters. Recover spilled materials on ncluding ignitable vapors, have been removed, thoroughly wet vacuum the area. DO NOT flush to sewer. If are bsorbents, such as sawdust or vermiculite, and sweep into closed containers for disposal. After all visible trace. ¡of spill is porous, remove as much contaminated earth, gravel, etc. as necessary and place in closed containers for disposal. <<>> NOV. 12 197 12:50 FROM FINANCE-DËPT TO 12023553753 PAGE.007 -. - Product Code No.: Product Name: 16-481 CLEANER FLUID, AEROSOL (Non-Flammable). Issue Date: Page: 1/9/96 5 of 7 SECTION VI - SPILL OR LEAK PROCEDURES •'HIGHWAY RAILWAY SPILLS*** (continued) (Collect) (202-483-7616) from Alaska & Hawaii Call CHEMTREC (1-800-424-930D) Cont. U.S. : the chemical materials and/or their containers in accordance with the Clean Air Act, the Resource Conservation chemical materials and/or their containers to prevent environmental contamination. It is your duty to dispose of SECTION VII - STORAGE AND SPECIAL PRECAUTIONS PRECAUTIONS TO BE TAKEN DURING HANDLING AND STORING: • • Trichloroethylene vapors are heavier than air and will collect in low areas. • DO NOT use in poorly ventilated confined spaces without proper respiratory protection (See Section 4). • Keep container closed when not in use. • Store only in closed, properly labeled container. • This material or its vapors when in contact with flames, hot glowing surfaces or electric arcs can decompose to - Liquid oxygen or other strong oxidants may form explosive mixtures with Trichloroethylene. form hydrogen chloride gas and traces of phosgene. • Avoid contamination of water supplies. Handling, storage and use procedures must be carefully monitored to avoid spills or leaks. Any spill or leak has the potential to cause underground water contamination which may, if sufficiently severe, render a drinking water source unfit for human consumption. Contamination that does occur cannot be easily corrected. OTHER PRECAUTIONS: • DO NOT breathe vapors. High vapor concentrations can cause dizziness, unconsciousness or death. Long- • Use only with adequate ventilation. Ventilation must be sufficient to limit employee exposure to term overexposure may cause liver/kidney injury and possible central nervous system damage. Trichloroethylene below permissible limits. Observance of lower limits is advisable (Outlined in Section 3). • Avoid contact with eyes. Will cause imtation and pain. Eye irritation, dizziness and/or drunkenness are signs of overexposure. • DO NOT swallow. Swallowing may cause injury or death. • Avoid prolonged or repeated contact with skin. May cause imitation or dermatitis. • DO NOT eat, drink or smoke in work areas. • When spraying mose than one half can continuously or more than one can consecutively, use NIOSH approved respirator. <<>> NOW 12 19? 12:51 FROM FINANCE-DEPT TO 12023563753 PAGE. 008 Product Name: Product Code No.: 16-481 CLEANER FLUID, AEROSOL (Non-Flammable) Issue Date: 1/9/96 Page: 6 of 7 SECTION VII - STORAGE AND SPECIAL PRECAUTIONS (continued) COMMENTS: TSCA - Trichloroethylene is on the TSCA inventory under CAS #79-01-6. SARA TITLE III - A) 311/312 categories - Acute and Chronic, 8) listed in Section 313 under Trichloroethylene, C) not listed as an "extremely hazardous substance in Section 302. CERCLA - Listed in Table 302.4 of 40 CFR Part 302 as a hazardous substance with a reportable quantity of 100 1-800-424-8802. pounds. Releases to air, land or water which exceed the RQ must be reported to the National Response Center. : RCRA - Waste Trichloroethylene and contaminated soils/materials from spill cleanup and U228 Hazardous Waste as per 40 CFR 261.33 (3) and 261.7 (B) (3) for cleaning requirements for empty containers. ANADIAN WHMIS - A) Sensitization to product: None known. B) Reproductiva Toxicity: None known ) Odor Threshold: Not known. D) Product Use: Adhesive • SECTION VIII - FIRE & EXPLOSION HAZARD DATA HAZARD RANKING NFPA HAZARD HEALTH HAZARD: CLASS FLAMMABILITY: 0 - Least 1 - Slight OTHER: 3 - High 2 - Moderate HMIS *- Chronic Health Effects HAZARD HEALTH HAZARD: CLASS FLAMMABILITY: PPE: FLASH POINT (METHOD USED): None when tested in accordance with DOT requirements. : FLAMMABLE LIMITS IN AIR (% BY VOLUME): LEL: 7.8% VEL: 52% EXTINGUISHING MEDIA: Water fog, dry chemicals or carbon dioxide. SPECIAL FIRE FIGHTING PROCEDURES: Fire fighters should wear NIOSH/MSHA approved pressure- demand, self-contained breathing apparatus for possible exposure to Hydrogen Chloride and possible traces containers. of Phosgene. Keep containers cooi. Use equipment or shielding required to protect against bursting or venting UNUSUAL FIRE AND EXPLOSION HAZARDS: Vapors concentrated in a confined or poorly ventilated area can be ignited upon contact with a high energy spark, flame, or high intensity source of heat. This can occur at or possible traces of Phosgene, Heated cans may burst. concentrations ranging between 7.8 - 52% by volume. Decomposition or burning can produce Hydrogen Chloride • <<>> NOV 12 ' 97 12:51 FROM FINANCE-DEPT TO 12023553753 PAGE .00S • 3. - • Product Name: Product Code No.: 16-481 CLEANER FLUID, AEROSOL (Non-Flammable) Page: Issue Date: 1/9/96 705 7 [SECTION IX - PHYSICAL DATA Vapor Density (Air=1): Boiling Point @ 760MM HG: 86-88C Solubility (Weight % in Water): Specific Gravity (H20 =1): 1.4 4.0 Volume % Volatile: 0.11 Vapor Pressure: 100 Evaporation Range: PSIG @ 70°F; 80 Appearance and Odor: (Butyl Acetate=1): > 1 Clear/Ethereal SECTION X - DOCUMENTARY INFORMATION ISSUE DATE: 1/9/96 PRODUCT CODE NO: 16-481 PREV. DATE: 5/28/93 PREV. PROD. CODE NO: 16-481 • MSDS NO: 0112 PREV. MSDS NO: N/A DISCLAIMER OF EXPRESSED AND IMPLIED WARRANTIES The information in this document is believed to be correct as of the date issued. HOWEVER, NO WARRANTY IS EXPRESSED OR IS TO BE IMPLIED REGARDING THE ACCURACY OR COMPLETENESS WARRANTY OF MERCHANTABILITY, FITNESS FOR ANY PARTICULAR PURPOSE, OR ANY OTHER information and product are furnished on the condition that the person receiving them shall make his OF THIS INFORMATION, THE RESULTS TO BE OBTAINED FROM HAZARDS RELATED TO ITS USE. This he assume the risk of his use thereof. own determination as to the suitability of the product for his particular purpose and on the condition that PREPARED BY: Marlo Carter -- ** TOTAL PAGE.009 ** <<>> SEP 12 '96 16:26 FR LOGISTICS 203 573 2736 TO 92023668700 - P.01 UNIROYAL. CHEMICAL COMPANY UNIROYAL MIDDLEBURY, CT. 06749 CHEMICAL FAX # 203-573-2377 PHONE # : 203-573-3702 TO: JENNIFER KARIm LOCATION: u.s. DoT FROM: Donald Hodder DATE: 9/12/96 Page(s) To Follow MESSAGE: PER OUR CONVERSATION I Am SENDING TEST RESULTS ON OUR PRODUCT CELOGEN AZ 120 THIs PRODUCT 1S PURE AZODICARBONAMIDE IN THE SMALLEST PARTICLE SIZE PLEASE ADVISE IF YOU NEEO ANy AODITIONAL INFORMATION detace <<>> SEP 12 '96 16:26 FR LOGISTICS 203 573 2736 TO 92023668700 P.02 STRESAU LABORATORY INC N8285 Medley Road, Spooner, Wi 54801, Tel. 715-635-2777, FAX 715-635-7979 : LABORACORY REPORT NO. 95099 ! "UNITED NATIONS TESTING" foI Uniroyal Chemical Co. Middlebury, CT 06749 World Headquarters USA Attn: Mr. Rhomie I. Heck III April 19, 1995 Prepared by: Vincent E. Mendoza Hazardous Materials Technician Review: Developnent Manager Over Thirty years of Duvelopment • Evaluation & Production of Energetic Devices Classification • Packaging • Testing of Hazardous Materiais <<>> SEP 12 '96 16:26 FR LOGISTICS 203 573 2736 TO 92023668700 P.03 : ". STRESAU LABORATORY, INC. April 19, 1995 LABORATORY REPORT NO. 95099 Page 1 of 4 Prepared for: Uniroyal Chemical Co. Middlebury, CI 06749 World Readquarters subject: "United Nations Testing" 1.0 Obiect A sample identified as Celogen AZ-120 was subjected to rganic Peroxide testing as requested in Uniroyal Chemical Purchase Order # 3352-05-147. with United Nations Transport of Dangerous Goods. Tests and specifically noted, all tests were conducted in accordance 2.0 PHYSICAL APPEARANCE The sample consisted of a light orange colored fine dry powder. 3.0 TESTS CONDUCTED 3.1 Gap Test for Organic Peroxides - Test A.3 Stresau test #1600A The pentolite was initiated by use of a #8 electric blasting cap. Ihree trials were performed. specific results as follows: In all three trials, partial fragmentation occurred, with the 1) 6 1/2" of pipe destroyed. The witness plate was dented. 2) 6 1/2" of pipe destroyed. The witness plate was dented. 3) 6 3/4" of pipe destroyed. The witness plate was dented. 3.2 Time I Pressure Test- Test C.1 Stresau test #1604 The sample was tested in accordance with the United Nations test method. The test was conducted three times. The results are as follows (copy of charts attached) : <<>> SEP 12 '96 16:27 FR LOGISTICS 203 573 2736 TO 92023668700 P.04 STRESAU LABORATORY, INC. April 19, 1995 LABORATORY REPORI NO. 95099 Page 2 of 4 #1: Pressure Iise exceeded 373.4 PSI in a time of 432 ms. #2: Maximum pressure rise of 371.9 PSI in a time of 336 ms. Pressure rise 100-304.7 PSI in 96 ms. #3: Pressure rise exceeded 375 PSI in a time of 308 ms. Pressure rise 100-303.1 PSI in 90 ms. Pressure rise 100-314.1 PSI in 68 ms. 3.3 Deflagration Test. - Test. E.2 Stresau test #1605 he sample was placed in a 14 mn diameter Pyxex ignition tub nd placed in a fume hood. A propane torch was ignited anc placed into the sample. The sample ignited and burned the was then repeated using a 28 mn Pyrex ignition tube, with a 50 mum test zone in a time of 3 minutes, 35 seconds. The test 50 mm burn time of 3 minutes, 15 seconds. Vessel. ine test was then repeated using a 0.5 liter Dewar results: Iwo trials were conducted with the following • 2: Burned 50mm without flame in 3 minutes, 15 seconds. 1: Burned 50mm without flame in 3 minutes, 21 seconds. 3.4 Dutsa Pressure Vessel Test. - Test E.2 Stresau test #1607 For the first trial, an aperture disc of 1 mm was used. A vessel. 10 g • sample oi the The tupture disc was positioned and secured with material was poured into the pressure flange bolts. A small amount of water was poured over the then positioned into the holder. rupture diso to keep it relatively cool. The test vessel was • On the first trial, the pressure disc ruptured. The vessel was cooled. and cleaned, and the test was repeated with a 1.2 mm aperture. The sample did not rupture" three times with the 1.2 mn: aperture. 3.5 United States Pressura Vessel Test:: Test E.3 Stresau test #1608 The rupture • disc was positioned and secured with flange bolts. A small amount of water was poured over the rupture diso : to keep it relatively cool. The test vessel was then positioned into the holder. <<>> - SEP 12 '96 16:27 FR LOGISTICS - 203 573 2735 TO 92023668780 P.Ø5 SIRESAU LABORATORY, INC. LABORATORY REPORT NO. 95099 April 19, 1995 Page 3 of 4 On the first trial, the disc did not rupture. The vessel was cooled and cleaned, and the test was repeated with an aperture opening of 1.5 mm, with the same results. The test was ther repeated with the 2.0 aperture three times, with no rupture. Thus, the USA-PVI number is 2.0. 3.6 Modified Trauz) Block Jest Stresau Test #1600I Nations The test was conducted in accordance with the United Transportation has recommended running reference tests US Department with the Trauzl Test. As this material is a solid, fine silicon sand was used for the reference material. with the results as follows: Three trials were conducted on the reference and sample, REFERENCE: 1: Expansion of 12ml 2: Expansion of 13ml 3: Expansion of 13ml Average Expansion 12.66ml SAMPLB: 1: Expansion of 18ml 3: Expansion of 17ml 2: Expansion of 15ml Average Expansion 16.06ml Average Expansion Sample minus Reference equals 4.0 ml. 4.O SUMMARY Following the flow chart in Section 1 of Part III of the United Nations Test & Criteria book: Box 1: The sample doest or solate a detonation as defined The sample is by the Time/Pressure test. Box 7: The sample is shown to have a "low" effect when heated under confinement by either the US Pressure Vessel or the Dutch Pressure Vessel Tests. <<>> SEP 12 '96 16:27 FR LOGISTICS 203 573 2736 TO 92023668700 P.06 - " STRESAU LABORATORY, INC. LABORATORI REPORI NO. 95099 April 19, 1995 Page 4 of 4 Box 8: The sample has no explosive power, as defined by the Modified Trauzl Test. Box 10: If exemption is desired you may refer to Box 7 data. Box 11: If exemption is desired you may refer to Box 1 data. This sumnary is prepared for customer information only. 5.0 DATA STORAGE The field data for this report is contained in Data Book #SLE original charts for the Time/Pressure Test are attached to the 95-1 and filed with Stiesau Laboratory's Document Control. The Stresau Hazardous Materials Department office copy of this report. After a period of one calendar year, the office copy transferred to Document • Control. No video oI photographic documentation was made. : ** TOTAL PAGE.06 ** ## Provenance - Official: Yes - Source: - Source ID: `phmsa` - SHA-256: `b7c2bf44e311bb7695ddf51e22fc297d15760ae0d403970253b9016a04ac129b` - Retrieved: 2026-08-20T00:59:31.977Z - Exported: 2026-08-25T22:19:38.532Z - Document slug: `phmsa-interpretation-98-0403` ### Source metadata ```json { "materialSubtype": "interpretation", "interpretationArea": "hazardous_materials", "representation": "full_text_from_official_pdf", "companies": [ "Myers Industries" ], "individuals": [ "Ms. Barb Germano" ], "refIds": [ "98-0403" ], "catalogDates": [ "1993-05-01" ], "catalogParts": [ 172 ], "catalogRowCount": 1, "sourceRecordUrls": [ "https://www.phmsa.dot.gov/node/68186" ], "linkedAttachmentUrls": [], "unavailableResponseUrls": [], "duplicateRepresentationUrls": [], "citedSections": [ "172.101", "173.22", "173.306(a)(3)", "171.12(b)", "171.8" ], "catalogPageUrls": [ "https://www.phmsa.dot.gov/regulations/title49/section/172101" ], "pdfUrls": [ "https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/1998/980403.pdf" ], "representations": [ { "viewUrl": "https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/1998/980403.pdf", "detailUrl": null, "detailHtmlPath": null, "pdfUrl": "https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/1998/980403.pdf", "pdfArtifactPath": "data/sources/phmsa-interpretations/98-0403-4c9ddf1474.pdf", "pdfArtifactSha256": "dd5ed3f849f20e7284d5732f60b46fd9883ef283f6da292c50fce6ea42d740b9", "extractedTextPath": "data/sources/phmsa-interpretations/98-0403-4c9ddf1474.v2.txt", "extractedTextSha256": "6cb6fe2274d6a00bdfb17e9da2632b14b37b34296be890622ee57452416080a4", "pageCount": 18, "extractionVersion": 2 } ], "caveat": "Interpretations apply regulations to the facts presented and do not create independently enforceable requirements.", "jurisdiction": "US" } ```