Air Products and Chemicals, Inc. — Hazardous Materials Safety Interpretation

Page 1Washington, D.C. 400 Seventh Street. S.W. 20590 Research and Special Programs Administratior OCT 2 7 2000 Mr. Donald R. Silfies Ref. No. 00-0256 Senior Safety Specialist 7201 Hamilton Boulevard Air Products and Chemicals, Inc. Allentown, Pennsylvania 18195 Dear Mr. Silfies: This responds to your letter, dated September 8, 2000, concerning regulatory requirements for transporting hydrogen fluoride, anhydrous. Specifically, you ask about labeling and placarding requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Your understanding of the HMR requirements for hydrogen fluoride, anhydrous, is correct. Because it meets the definition of a material poisonous by inhalation (PIH) in § 171.8, shipments of hydrogen fluoride, anhydrous, must conform to specific shipping paper, package marking, and placarding regulations applicable to PIH materials. Thus, the shipping paper must include the words "Poison - Inhalation Hazard, Zone C" immediately following the shipping description (§ 172.203(m)(3)). Further, the package must be marked "Inhalation Hazard" (§ 172.313(a)). In addition, the transport vehicle or freight container must be placarded with a POISON INHALATION HAZARD placard in addition to any other required placards (§ 172.505(a)). You are also correct that the labels required under the HMR for packages containing hydrogen fluoride, anhydrous, do not communicate that it is a PIH material. As you note, the regulations require a CORROSIVE label to indicate the material's primary hazard and a POISON label to indicate the material's subsidiary hazard. These requirements are consistent with international regulations in the UN Recommendations on the Transport of Dangerous Goods. The HMR permit you to apply labels in addition to those listed in the Hazardous Materials Table (HMT) for a given hazardous material provided the label accurately represents a hazard of the INHALATION HAZARD label in addition to the CORROSIVE and POISON labels listed in hazardous material in the package. For hydrogen fluoride, anhydrous, you may use a POISON Column (6) of the HMT. 172,313 000256#

Page 2We agree with you that the current HMR requirements for labeling packages of hydrogen fluoride, anhydrous, are confusing and do not accurately convey the hazard presented by the material. We plan to address this confusion in an upcoming rulemaking. I hope this information is helpful. If you have further questions, please do not hesitate to contact this office. Sincerely, I.Allar Thomas G.Allan Senior Transportation Regulations Specialist Office of Hazardous Materials Standards#

Page 3sorske PRODUCTS E $ 172.313 Marking Labelin 201 Hamilton Bouleva ir Products and Chemicals, In Allentown, PA 18195-1501 Telephone (610) 481-4911 Placarding Research and Special Programs Administration September 8, 2000 Office of Hazardous Materials Standards (DHM-10) 400 Seventh Street, SW. U.S. Department of Transportation Washington, D.C. 20590-0001 Subject: Request for Clarification Hydrogen Fluoride Labeling Dear Sir or Madam, labeling and placarding requirements for Hydrogen Fluoride, Anhydrous. I am writing this letter to request an official clarification regarding the current USDOT regulations that apply to the The 49 CFR 172.101 Table states that Hydrogen Fluoride, Anhydrous is classified as a Corrosive material, Hazard Hydrogen Fluoride is a material poisonous by inhalation in Hazard Zone C. Class 8, in Packing Group I. The table lists a subsidiary hazard of 6.1 and also Special Provision Code 3 stating that The confusion comes into play in respect to the marking, labeling and placarding for the subsidiary inhalation hazard. inhalation hazard Zone A or B, is POISON (ref. 172.430). Using this information, it is our interpretation that in The Labeling table, shown in paragraph 172.400(b), specifies that the label for a Division 6.1 material other than addition to the primary CORROSIVE (8) label, the subsidiary label for Hydrogen Fluoride is POISON (6.1). with the phrase, "Inhalation Hazard. The Marking regulations specify in paragraph 172.313(a) that materials poisonous by inhalation must be marked Hazard" phrase appears on the label, the "Inhalation Hazard" marking is not required on the package. The last sentence of this paragraph also states that when the "Inhalation According to subparagraph 172.203(m)(2) of the Shipping Paper regulations, Hydrogen Fluoride is subject to the additional description requirements for materials that are poisonous by inhalation. transport vehicles containing materials subject to the "Poison Inhalation Hazard" shipping description must be In determining the additional subsidiary Placarding requirements, it is specified in paragraph 172.505(a) that placarded with a POISON INHALATION HAZARD or POISON GAS placard, as appropriate. To quickly summarize, the marking, labeling, shipping paper, and placarding regulations specify the following: • 1) The container must be marked with the phrase "Inhalation Hazard" because the material is poisonous by 2) The cylinder must be labeled with a subsidiary POISON label, but not POISON INHALATION HAZARD inhalation. NOTE: This marking would not be necessary however, if the label displayed the same phrase. because the Hazard Zone is not A or B. 3) The HM Shipping Paper description must include the phrase, "Poison-Inhalation Hazard", and 4) The transport vehicle must display a subsidiary POISON INHALATION HAZARD placard because the material is poisonous by inhalation. 1#

Page 4because the label must be the POISON label. Yet, the transport vehicle must display a subsidiary POISON Although the cylinder must display the phrase "Inhalation Hazard", the phrase cannot be displayed on the label INHALATION HAZARD placard, even though the subsidiary label is a POISON label. subsidiary hazard is division 6.1 with an assigned inhalation hazard zone other than Zone A or B. It is also the only To the best of our knowledge, this is the only hazardous material listed in the entire 172.101 Table where the material in the 172.101 Table where the mandated label and placard do not agree. Jsing data as published in Pamphlet P-20 from the Compressed Gas Association, Inc., an analysis of comparable lazardous materials with inhalation hazards reveals the following interesting facts Item Haz Class Sub Risk Haz Zone LC50 Value Hydrogen Chloride Hydrogen Fluoride 23 8 6.1 1,276 ppm Hydrogen Bromide 2.3 8 8 3,120 pm 2,860 ppm Sulfur Dioxide Carbon Monoxide 2.3 2.3 8 2.1 D 3,760 ppm 2,520 ppm In evaluating the above listed information, it is obvious that although Hydrogen Fluoride is assigned a Primary risk (inhalation hazard) value, it seems odd that the subsidiary risk label for Hydrogen Fluoride would not communicate of Corrosive (8), the inhalation toxicity is actually greater than the other gases listed. Based on the toxicity this hazard, yet, the primary risk label for gases that are less toxic do communicate the inhalation hazard. In summary: Considering 1) the above mentioned toxicity data, 2) that the regulations require containers of the phrase, "Poison-Inhalation Hazard", and 4) that the transport vehicle must be placarded with subsidiary POISON Hydrogen Fluoride to be marked with the phrase "Inhalation Hazard", 3) that the HM Shipping Paper must include INHALATION HAZARD placards, it is our opinion that the display of a subsidiary POISON label is contradictory and that the POISON INHALATION HAZARD label would be more appropriate, far less confusing, and would help to accurately communicate the hazard for this product. It is very difficult for shipping personnel and carriers to understand and remember that for Hydrogen Fluoride, the placards offered and displayed must be different than the labels on the cylinder. exception to the rule. We would sincerely appreciate your prompt response to this matter. We are hopeful that after careful consideration, you agree with our assessment. We believe that this material is an Respectfully submitted, Donald R. Silfies Senior Safety Specialist Air Products & Chemicals, Inc. E-Mail: silfiedr@apci.com PH: (610) 481-6477 2 -#