Chemtech Finishing System — Hazardous Materials Safety Interpretation

Page 1of Transportation J.S. Department 400 Seventh Street, S.W. Washington, D.C. 20590 Special Programs Research and Administration NOV 7 2000 Ms. Stephanie Williams Regulatory Affairs Engineer Ret. No. 00-0306 Chemtech Finishing System 23177 Commerce Drive Farmington Hills, Michigan 48335 Dear Ms. Williams: This responds to your letter, dated October 31, 2000, concerning transportation of lithium hydroxide under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if you may rename a technically pure shipment of lithium hydroxide as a lithium hydroxide mixture or a corrosive solid mixture, n.o.s., in order to protect a trade secret. The answer is no. As defined in the HMR, a "mixture" means a material composed of more than one chemical compound or element (see § 171.8). Technically pure lithium hydroxide is not a mixture and may not be so described on a shipping paper. Further, generic shipping names, such as corrosive solid, n.o.s., are to be used only for hazardous materials not specifically listed by name in the Hazardous Materials Table. As your letter notes, lithium hydroxide, solid, is listed in Column (2) of the table. Thus, the shipping description for technically pure lithium hydroxide is: Lithium hydroxide, solid, 8, UN 2680, PG II. I hope this information is helpful. If you have further questions, please do not hesitate to contact this office. Sincerely, The oH. Allar Thomas G. Allan Senior Transportation Regulations Specialist Office of Hazardous Materials Standards#

Page 2OCT-30-2000 18:04 CHEMTECH FINISHING SYSTEM 248 478 6810 P.01/01 23177 Commerce Drive Farmington Hills, Mi 48335 Gosky Phone: 248.478.5200 x 235 FAX: 248.478.6810 172.10| Chemtech. Finishing Systems October 31, 2000 Proper Shipping Nam Director for the Office of Hazardous Material Standards Mr. Edward Mazzullo 00-0306 United States Department of Transportation/ Research & Special Programs Administration 400 7* Street SW Washington, DC 20590-0001 Dear Sir: I am writing this letter in order to get clarification on the definitions of mixture and solution. As defined in • 49 CFR 171.8 (Rev. as of 10/01/99) the following definitions are used: Mixture means a material composed of more than one chemical compound or element Solution means any homogenous liquid mixture of two or more chemical compounds or elements that will not undergo any segregation under conditions normal to transportation. The following scenario is what has occurred at my place of employment; We have a product that is a repack and relabel of a raw material, lithium hydroxide. This compound is listed on the 172.101 Hazardous Material Table. The proper shipping name would be: Lithium hydroxide, solid, 8,UN2680, PG II What we would like to know is the following: 1. Is there an alternative way to name this technically pure material, such that it does not reveal a trade secret and still stay DOT compliant? For example: a.) Lithium hydroxide solid mixture, 8, UN2680, PG II b.) Corrosive solid mixture, 8, UN2680, PG II (Contains Lithium hydroxide) An answer as soon as possible would be greatly appreciated in order to keep a customer. Sincerely, Regulatory Affairs Engineer Stephanie Williams • TOTAL P.Ø1#

Page 3DETECTOR - LYMAN ALPHA SILVER CHLORIDE BOND (Model No. GT 203D) MAGNESIUM FLUORIDE WINDOW ROUNDED END 13 O.D. × 1MM THK , EVAPORATED METAL COATING 22 MM 9MM$0.5 PYREX FILL DETECTOR WITH 3 16MM NITRIC OXIDE (NO) - 30 MM +— 12 MM#