{"operation":"document","citation":"00-0256","title":"Air Products and Chemicals, Inc. — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2000-10-27","effective_on":null,"summary":"00-0256 response to Air Products and Chemicals, Inc. concerning 172.313.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-00-0256.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-00-0256.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-00-0256","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2000/000256.pdf","body":"<<<PAGE 1>>>\n\nWashington, D.C.\n400 Seventh Street. S.W.\n20590\nResearch and\nSpecial Programs\nAdministratior\nOCT 2 7 2000\nMr. Donald R. Silfies\nRef. No. 00-0256\nSenior Safety Specialist\n7201 Hamilton Boulevard\nAir Products and Chemicals, Inc.\nAllentown, Pennsylvania 18195\nDear Mr. Silfies:\nThis responds to your letter, dated September 8, 2000, concerning regulatory requirements for\ntransporting hydrogen fluoride, anhydrous. Specifically, you ask about labeling and placarding\nrequirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).\nYour understanding of the HMR requirements for hydrogen fluoride, anhydrous, is correct.\nBecause it meets the definition of a material poisonous by inhalation (PIH) in § 171.8, shipments\nof hydrogen fluoride, anhydrous, must conform to specific shipping paper, package marking, and\nplacarding regulations applicable to PIH materials. Thus, the shipping paper must include the\nwords \"Poison - Inhalation Hazard, Zone C\" immediately following the shipping description\n(§ 172.203(m)(3)). Further, the package must be marked \"Inhalation Hazard\" (§ 172.313(a)). In\naddition, the transport vehicle or freight container must be placarded with a POISON\nINHALATION HAZARD placard in addition to any other required placards (§ 172.505(a)).\nYou are also correct that the labels required under the HMR for packages containing hydrogen\nfluoride, anhydrous, do not communicate that it is a PIH material. As you note, the regulations\nrequire a CORROSIVE label to indicate the material's primary hazard and a POISON label to\nindicate the material's subsidiary hazard. These requirements are consistent with international\nregulations in the UN Recommendations on the Transport of Dangerous Goods.\nThe HMR permit you to apply labels in addition to those listed in the Hazardous Materials Table\n(HMT) for a given hazardous material provided the label accurately represents a hazard of the\nINHALATION HAZARD label in addition to the CORROSIVE and POISON labels listed in\nhazardous material in the package. For hydrogen fluoride, anhydrous, you may use a POISON\nColumn (6) of the HMT.\n172,313\n000256\n\n<<<PAGE 2>>>\n\nPage 2\nWe agree with you that the current HMR requirements for labeling packages of hydrogen\nfluoride, anhydrous, are confusing and do not accurately convey the hazard presented by the\nmaterial. We plan to address this confusion in an upcoming rulemaking.\nI hope this information is helpful. If you have further questions, please do not hesitate to contact\nthis office.\nSincerely,\nI.Allar\nThomas G.Allan\nSenior Transportation Regulations Specialist\nOffice of Hazardous Materials Standards\n\n<<<PAGE 3>>>\n\nsorske\nPRODUCTS E\n$ 172.313\nMarking Labelin\n201 Hamilton Bouleva\nir Products and Chemicals, In\nAllentown, PA 18195-1501\nTelephone (610) 481-4911\nPlacarding\nResearch and Special Programs Administration\nSeptember 8, 2000\nOffice of Hazardous Materials Standards (DHM-10)\n400 Seventh Street, SW.\nU.S. Department of Transportation\nWashington, D.C. 20590-0001\nSubject: Request for Clarification\nHydrogen Fluoride Labeling\nDear Sir or Madam,\nlabeling and placarding requirements for Hydrogen Fluoride, Anhydrous.\nI am writing this letter to request an official clarification regarding the current USDOT regulations that apply to the\nThe 49 CFR 172.101 Table states that Hydrogen Fluoride, Anhydrous is classified as a Corrosive material, Hazard\nHydrogen Fluoride is a material poisonous by inhalation in Hazard Zone C.\nClass 8, in Packing Group I. The table lists a subsidiary hazard of 6.1 and also Special Provision Code 3 stating that\nThe confusion comes into play in respect to the marking, labeling and placarding for the subsidiary inhalation\nhazard.\ninhalation hazard Zone A or B, is POISON (ref. 172.430). Using this information, it is our interpretation that in\nThe Labeling table, shown in paragraph 172.400(b), specifies that the label for a Division 6.1 material other than\naddition to the primary CORROSIVE (8) label, the subsidiary label for Hydrogen Fluoride is POISON (6.1).\nwith the phrase, \"Inhalation Hazard.\nThe Marking regulations specify in paragraph 172.313(a) that materials poisonous by inhalation must be marked\nHazard\" phrase appears on the label, the \"Inhalation Hazard\" marking is not required on the package.\nThe last sentence of this paragraph also states that when the \"Inhalation\nAccording to subparagraph 172.203(m)(2) of the Shipping Paper regulations, Hydrogen Fluoride is subject to the\nadditional description requirements for materials that are poisonous by inhalation.\ntransport vehicles containing materials subject to the \"Poison Inhalation Hazard\" shipping description must be\nIn determining the additional subsidiary Placarding requirements, it is specified in paragraph 172.505(a) that\nplacarded with a POISON INHALATION HAZARD or POISON GAS placard, as appropriate.\nTo quickly summarize, the marking, labeling, shipping paper, and placarding regulations specify the following:\n•\n1) The container must be marked with the phrase \"Inhalation Hazard\" because the material is poisonous by\n2) The cylinder must be labeled with a subsidiary POISON label, but not POISON INHALATION HAZARD\ninhalation. NOTE: This marking would not be necessary however, if the label displayed the same phrase.\nbecause the Hazard Zone is not A or B.\n3) The HM Shipping Paper description must include the phrase, \"Poison-Inhalation Hazard\", and\n4) The transport vehicle must display a subsidiary POISON INHALATION HAZARD placard because the\nmaterial is poisonous by inhalation.\n1\n\n<<<PAGE 4>>>\n\nbecause the label must be the POISON label. Yet, the transport vehicle must display a subsidiary POISON\nAlthough the cylinder must display the phrase \"Inhalation Hazard\", the phrase cannot be displayed on the label\nINHALATION HAZARD placard, even though the subsidiary label is a POISON label.\nsubsidiary hazard is division 6.1 with an assigned inhalation hazard zone other than Zone A or B. It is also the only\nTo the best of our knowledge, this is the only hazardous material listed in the entire 172.101 Table where the\nmaterial in the 172.101 Table where the mandated label and placard do not agree.\nJsing data as published in Pamphlet P-20 from the Compressed Gas Association, Inc., an analysis of comparable\nlazardous materials with inhalation hazards reveals the following interesting facts\nItem\nHaz Class\nSub Risk\nHaz Zone\nLC50 Value\nHydrogen Chloride\nHydrogen Fluoride\n23\n8\n6.1\n1,276 ppm\nHydrogen Bromide\n2.3\n8\n8\n3,120 pm\n2,860 ppm\nSulfur Dioxide\nCarbon Monoxide\n2.3\n2.3\n8\n2.1\nD\n3,760 ppm\n2,520 ppm\nIn evaluating the above listed information, it is obvious that although Hydrogen Fluoride is assigned a Primary risk\n(inhalation hazard) value, it seems odd that the subsidiary risk label for Hydrogen Fluoride would not communicate\nof Corrosive (8), the inhalation toxicity is actually greater than the other gases listed. Based on the toxicity\nthis hazard, yet, the primary risk label for gases that are less toxic do communicate the inhalation hazard.\nIn summary: Considering 1) the above mentioned toxicity data, 2) that the regulations require containers of\nthe phrase, \"Poison-Inhalation Hazard\", and 4) that the transport vehicle must be placarded with subsidiary POISON\nHydrogen Fluoride to be marked with the phrase \"Inhalation Hazard\", 3) that the HM Shipping Paper must include\nINHALATION HAZARD placards, it is our opinion that the display of a subsidiary POISON label is contradictory\nand that the POISON INHALATION HAZARD label would be more appropriate, far less confusing, and would\nhelp to accurately communicate the hazard for this product.\nIt is very difficult for shipping personnel and carriers to understand and remember that for Hydrogen Fluoride, the\nplacards offered and displayed must be different than the labels on the cylinder.\nexception to the rule. We would sincerely appreciate your prompt response to this matter.\nWe are hopeful that after careful consideration, you agree with our assessment. We believe that this material is an\nRespectfully submitted,\nDonald R. Silfies\nSenior Safety Specialist\nAir Products & Chemicals, Inc.\nE-Mail: silfiedr@apci.com\nPH: (610) 481-6477\n2\n-","truncated":false,"body_characters":8181}