Environmental Health and Safety — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department Washington, D.C. 20590 400 Sevanth St., S.W. Research and Special Programs Administration • JUL 2 6 2001 Mr. Dan Smith Senior Product Specialist Reference No.: 01-0160 Environmental Health and Safety Ashland, Inc. • P. O. Box 2219 Columbus, OH 43216 Dear Mr. Smith: This is in response to your letter regarding the placement of technical and chemical group names in shipping descriptions under the Hazardous Materials Regulations (49 CFR Parts 171-180). Specitically, you ask it the placement of technical and chemical group names between the proper shipping name and hazard class applies to any proper shipping name as long as the information is appropriate and not inconsistent with the proper shipping name. The answer is yes. Section 172.202(d) authorizes, without limitations, the placement of technical and chemical group names between the proper shipping name and hazard class. Xylene may be described as "Xylenes (Xylene, Ethyl Benzene), 3, UN1307, PG III". I trust you find this information helpful. Sincerely, Watte I mitte ll Hattie L. Mitchell Chief, Regulatory Review and Reinvention Office of Hazardous Materials Standards#

Page 2G. W. Hammer Enronmental. Health and Safery Vice Presıdent Ashland Inc. ASHLAND. Fax (614) 790-6080 Tel: (614)790-3052 PO Box 2219 wswwashland.com Columbus OH 43216 Corbin $172.202 (d) RSPA Office of Hazardous Materials Standards (DHM-10) U.S. Department of Transportation Papers 400 Seventh St. SW Shipping Washington, DC 20590-0001 RE: Shipping Papers The purpose of this letter is to respectfully request that RSPA review certain provisions of the Hazardous Materials Regulations and issue a written opinion on the questions presented below. Section 172.202(d) states that "technical and chemical group names may be entered in parentheses between the proper shipping name and hazard class".... Our understanding is that this applies to any proper shipping name as long as the information is appropriate and not inconsistent with the proper shipping name. For example, Xylenes, a proper shipping name listed on the Hazardous Materials Table usually consists of o-xylene, p-xylene and ethylbenzene as well as small quantities of toluene. (See attached manufacturing information). In accordance with 172.202(d), we believe the following shipping paper description is appropriate for this material. Xylenes (Xylene; Ethyl Benzene) 3, UN1307, PG III Your written opinion and comments are appreciated. Please advise if you require any additional information. Sincerely, Dan Smith Dan Smith Senior Product Specialist Environmental Health and Safety#

Page 3... taken from TOXNET - Hazardous Substances Database http://toxnet.nlm.nih.gov/cgi-bin/sis/search/f7./temp/~BAAjWaGLP:1 General Manufacturing Information: The commerical product mixed xylenes (a technical product generally containing 20% each of o-xylene, p-xylene and ethylbenzene, as well as small quantities of toluene) analogously to toluene is an agent of major chemical and occupational significance. It is produced in very large quantities and is extensively employed in a broad spectrum of applications, primarily as a solvent for which its use is increasing as a safe replacement for benzene, and in gasoline as part of the BIX component (benzene-toluene-xylene); xylenes are also trequently used in the rubber industry with other solvents such as toluene and benzene. As individual isomers they are extensively employed in the synthesis of synthetic agents. For example, phthalic acid, isophthalic acid, terephthalic acid, and diemthylterephthalate have very broad applications in the further preparation of phthalate ester plasticizers and components of polyester fiber, film and fabricated items. ... Compared with benzene and toluene, very much less is known of the human health isomers or in admixture with other alkylbenzenes. nazards, particularly the chronic ettects of xylenes, either as mixed xylenes, as individual [Fishbein L; Sci Total Environ 43 (1-2): 165-83 SECushiman (1985) ]**PEER REVIEWED** нт.. ... Xylene produced from petroleum ... contains approx 20% o-xylene, 44% m-xylene, 7/35/07 20% p-xylene and 15% ethylbenzene. Xylene from coal tar generally consists of 10-15% ortho-, 45-70% meta-, 23% para-, and 6-10% ethylbenzene. NIOSH 75-168]**PEER REVIEWED** [NIOSH; Criteria Document: Xylene p.14 (1975) DHEW Pub.#

Page 4Ashland Ashland Distribution Company GLUMNO Division of Ashland Inc. PRESOSTED P.O. Box 2219 REST CLASS N2101 Columbus, OH 43216 710799 TO METI RSPA Office of Hazardous Materials Standards (DHM-10) U.S. Department of Transportation 400 Seventh St. SW Washington, DC 20590-0001 D-2 •AUME ......#