Horning's Incorporated — Hazardous Materials Safety Interpretation

Page 1of Transportation US.Department Washington, D.C. 400 Seventh Street, S.W. 20590 Research and Special Programs Administration MAR 3 0 2000 Ms. Kathy M. Koppe Horning's Incorporated Ref. No. 00-0065 P.O. Box 88416 Indianapolis, IN 46208 Dear Ms. Koppe: in response to your letter dated February 24, 2000 Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) to requesting information concerning the applicability of several materials. Under § 173.22, it is a shipper's responsibility to determine a material meets the definition of the listed hazard class or is not subject to the HMR. Such determinations are not required to be verified by this office nor does the Department have resources to perform routine verifications. I hope this satisfies your request. Sincerely, John A. Gale Transportation Regulations Specialist Office of Hazardous Materials Standards 000065 173.22#

Page 2HORNING'S BAH $173.22 INCORPORATED 00-0065 QUALITY CLEANING PRODUCTS 1176 W. 28th Street (317) 926-1267 Indianapolis, IN 46208 P. O. Box 88416 1-800-633-1409 February 24, 2000 Fax (317) 921-7762 U.S. Department of Transportation Research and Special Programs Administration 400 7" Street SW Attn: Office of Hazardous Materials Standard: Washington, DC 20590 Re: Request for Interpretation Dear Sirs, I would like to request an interpretation and definition of the following chemicals. Please include with this material class 8. information what the guidelines are for shipping names and the guidelines for shipping as a corrosive however, after running tests on our product it seems as if it may not fall within your guidelines as corrosive. Under the current ruling "HM-215A" it appears as if the products must be shipped as a corrosive material, Metasilicate both Anhydrous and Pentahydrate are subject to a name change in shipping. With regards to According to the MSDS it is not a corrosive. We have also located information that states Sodium the name change, what are the current guidelines? Are these products subject to the name change as a "raw Please research the following; Sodium Metasilicate Anhydrous Sodium Metasilicate Pentahydrate Disodium Trioxosilicate Pentahydrate Corrosive Solid Basic, Inorganic, N.O.S. Thank you for you assistance in this matter and we are looking forward to your response. If you should need any further information, please feel free to contact either Mathew or Jim Horning at 317-926-1267. Sincerely, Kathy M. Koppе-т4 Kathy M. Koppe Risk Manager Bob Quillanan DOT - Office of Hazardous Materials Enforcement Cc: Hornings Inc. REPRESENTING: LEVER BROTHERS • PROCTER & GAMBLE • COLGATE-PALMOLIVE GORAIA PACIFIC. PAPER PRONUCTS MERMAPED LOUIN HAND SOARS.....#