Huntsman Corporation — Hazardous Materials Safety Interpretation

Page 1US.Department of Transportation 400 Seventh Street, S.W. Washington, D.C. 20590 Research and pecial Program dministratio JUN 1 4 2000 Mr. Philip Abraham Ref. No. 00-0096 Room 501 Huntsman Corporation 3040 Post Oak Blvd. Houston, IX 77056 Dear Mr. Abraham: This is in response to your letter dated March 30, 2000, regarding determination of a proper shipping name under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask whether "Amines, liquid, corrosive, flammable, n.o.s. (Technical name), 8, UN 2734, PG II" is the most appropriate shipping description for an amine that meets the HMR criteria for Class 8 Packing Group II, Class 3 Packing Group III, and Division 6.1 Packing Group III? The answer is yes.. Section 172.101 (c) (12) (iii) states that if the material meets the definition of more than one hazard class and is not identified specifically by name in the Hazardous Materials Table, then the hazard class of the material shall be determined by using the precedence specified in S 173.2a. In your scenario, Class 8 Packing Group II takes precedence followed by Class 3 Packing Group III, then Division 6.1 Packing Group III. Therefore, the proper shipping description for the hazardous material is "Amines, liquid, corrosive, flammable, n.o.s. (Technical name), 8, UN 2734, PG II." In addition, subsidiary hazard class or division numbers may be entered following the numerical hazard class, or following the basic description ($ 172.202 (a) (2)). Section 172.203 (m) states that if a material meets the definition of Division 6.1, Packing Group I or II, and the fact that it is toxic is not disclosed in the shipping name or class entry, then the word "Poison" or "Toxic" shall be entered on the shipping paper in association with the shipping 172.203 000096#

Page 2- description. Therefore, the term "Poison" or "Toxic" does not have to be included in the proper shipping description for a material that meets the definition for Division 6.1 Packing Group III. However, § 172.402 (a) (2) states that for a material meeting Division 6.1 (regardless of the packing group), a POISON hazard label is required in addition to any other required labels. I hope this satisfies your request. Sincerely, Transportation Regulations Specialist Office of Hazardous Materials Standards#

Page 3BAH 172.203 Philip Abraham 000096 Rm. 501 Huntsman Corporation Houston. IX. 77056 3040 Post Oak Blyd. March 30, 2000 Mi. Edward Mazzullo US DOT RSPA 400 7 Street SW Office of Hazardous Materials Standards Washington D.C., 20590 Dear Mr. Edward Mazzullo: hazard and Flammable (3 - PG III) and Oral or Dermal Toxic (6.1 - PG Ill, not a PIH) as the We have to ship a liquid product in drums which is Corrosive (8 - PG Il) as the Primary Subsidiary hazards. In the Hazardous Material Table (HMT) 172.101 there is a generic ¿we need additional PSN's listed in the HMT - Corrosive liquid, flammable, toxic, n.o.s and proper Shipping Name (PSN) listing - "Flammable liquid, toxic, corrosive, n.o.s".. However, Amines. iquid, corrosive, flammable, toxic, n.o.s. 1). Currently for the product, we are using a product specific PSN - "Amines, liquid, Hazard is not covered in such a description. How do we ship this product in compliance with corosive, lammable, n.o:s. (Technical name), 8, 3, UN. 2734 GIl. However, the Toxic What would be the PSN that we would use, to ship this product in DOT compliance, which DOTirsuch'a PSN is not listed in the HMT? Are we required to add the toxic hazard label? includes Corrosive as the primary hazard, Flammable and Toxic as the subsidiary hazards? What is the procedure to find the precedence of hazards when there is more than two hazards for a product? Please respond to this as soon as you can - we have a shipment due out very soon of this product, and we want to be DOT compliant in regards to shipping this product. Thank You Sincerely, ое в Philip Abraham, Tel. # 713 235 6025 ..... 10.12 0002-62-H#