Delta Analytical Corporation — Hazardous Materials Safety Interpretation

Page 1- Washington, D.C 400 Seventh Street. S.W. 20590 Seei rograms Administration APR | 9 2000 Mr. T. Jeff Jones Ref. No. 00-0073 Delta Analytical Corporation 7910 Woodmont Avenue, Suite 1000 Bethesda, Maryland 20814 Dear Mr. Jones: This is in response to your letter dated February 22, 2000, regarding whether sodium hypochlorite solutions containing less than 5.25% and 6.8% available chlorine is subject to the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You provided data for both the 5.25% and 6.8% sodium hypochlorite solutions. Based on the data you provided, this Office concurs with your opinion that both of the sodium hypochlorite solutions containing less than 5.25% and 6.8% available chlorine, respectively, would not be classed as corrosive material in accordance with the definition specified in 49 CFR 173.136. Thus, your products, containing these amounts of sodium hypochlorite solutions, are not subject to the requirements of the HMR for purposes of transportation in commerce. I hope this satisfies your inquiry. If we can be of further assistance, please contact us. Sincerely, Delmer F. Billings Chief, Standards Division Office of Hazardous Materials Standards 000073 1132°#

Page 2Engum ANALYTICAL DELTA = CORPORATION $173.22 00-0073 February 22, 2000 Mr. Delmer F. Billings Chief, Standards Development Office of Hazardous Material Standards 1S Sent re aporation Washington, DC 20590 Re: Corrosivity of Sodium Hypochlorite Solutions; Your Letter of October 7, 1999 Dear Mr. Billings: Thank you for your letter of October 7, 1999. After receiving your letter, my client, KIK Corporation, tested both 5.25% and 6.8% sodium hypochlorite solutions for corrosivity at Product Safety Labs, East Brunswick, NJ. The results of those studies are attached. The conclusion of both studies was that "Inlo siga of dermal corrosion was noted at any of the treated sites." Assuming on review that you agree with the conclusions of these studies, I would appreciate your issuing a letter confirming the Department's conclusion that the sodium hypochlorite solutions tested are not corrosive materials within the meaning of current regulatory guidelines. That letter would be patterned after the letter issued to The Clorox Company on February 6, 1991, which we've discussed in previous correspondence (attached). Thank you for your quick attention to this matter. If you need additional information, please contact me at your earliest convenience. Sincerely, frones T. Jeffrey Jones Enclosures 7910 Woodmont Avenue (301) 652-5495 Suite 1000 Bethesda, Maryland 20814 FAX (301) 652-5408#