W. R. Grace Co.-Conn — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department 400 Seventh St., S.W. Washington, D.C. 2059C Research and Special Programs Administration Ост 2 2 2001 Mr. Michael P. DeCicco Ref No. 01-0178 Polyolefin Catalyst Research and Development W. R. Grace Co.-Conn 7500 Grace Drive Columbia, Maryland 21044-4098 Dear Mr. DeCicco: This responds to your letter dated July 13, 2001, regarding classification of two products that were tested according to the UN Manual of Tests and Criteria as prescribed in § 173.124 of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Tests were performed by an outside laboratory which issued a report stating that one product, when testing laboratory concluded that a second product does not meet the criteria for a Division 4.3 shipped in containers of less than 3000L, does not meet the criteria for a Division 4.2 material. The material. You state that these products meet Division 4.1 (flammable solid) criteria, but disagree with the laboratory's test conclusions. You are of the opinion that these products should more appropriately be classed as Division 4.2 (spontaneously combustible) and Division 4.3 (dangerous when wet), respectively. This Office recognizes the "UN Manual of Tests and Criteria," prescribed in the definitions for Division 4.2, and 4.3 hazards in § 173.124, as the standard for determining the appropriate classifications in the Class 4 hazard class. Tests in § 173.124 are intended to be carried out under ambient conditions. Therefore, you may rely on the laboratory's tests results to classify your products as only meeting the Division 4.1 criteria. However, if additional information indicates your products react in a unique way to pose Division 4.2 or Division 4.3 hazards, you may take the worst case scenario to classify them as Division 4.2 or Division 4.3, in addition to Division 4.1. I hope this satisfies your inquiry. If we can be of further assistance, please contact us. Sincerely, Delmer F. Billings Chief, Standards Development Office of Hazardous Materials Standards 173.124 010178#

Page 2• _3/2001 11:16 FAX 410 531 4440 WR GRACE ฿02 Engrum $|13.124 Director of Hazardous Materials Standards Class Research and Special Programs Administration 400. I Ste st of Transportation 01-0178 Dear Mr. Mazzullo: han are detain a sit me in detes as 4, 12 and a ted isi cut on of al rein., re as follows The lab issued a report stating that our material, when shipped in containers less than 30001 1. 4.2 (Self-Heating) - We sent a catalyst sample out to be evaluated by an outside laboratory should not be classified as 4.2. The test was conducted as per the UN Manual of Tests and Criteria, increase. My concera is that, although our material did not exceed the 60C increase which is require which calls for a sample to be heated to 140 and then monitored for any internal material temperature for a 4.2 classification, if the test were performed at room temperature our material would increase exposure to air, our material does heat up. It does not, however, ever exceed the 200C limit 60C. The UN Manual does not require a test at room tempetature, but we do know that, upon 4.2, or should we take into consideration the fact that we know it does self-heat to some degree which is required for a 4.2 test. Would we be correct to follow the labs advice and not classify at room tempernture and consider classifying it 4.2? even if it is self-heating, be tested under an inert atmosphere when testing for water reactivity. The B. 4.3 (Water-Reactive) - Our maia concern with this test it that it does not specify that the material, test, when performed under the UN Manual guidelines, allows for the material to be tested under ambient conditions, which allows the material to deactivate somewhat prior to the water being arobient conditions, will begin to deactivate and that any time elapsed prior to the introduction introduced to the material. In other words, we know that the material, once it is introduced to of the water will adversely affect the amount of flammable gases that are emitted from the procedure, as outlined by the UN Manual on Tests and Criteria, will result in the "worst solid once the water comes into contact with it. Once again, we do not think that the test that any spilled material, and resulting flatmable gases emitted, would almost certainly case scenario" results that we anticipated. The test does, however, seem to take into account protecting people from the hazard the test being conducted under ambient conditions makes take place out in the open, not under an inert atmosphere, and for the purpose of sense. The manual is very ambiguous as to whether or the testing facility (Safety Consulting Engineers) and Richard Tarr, D.O.T., seer to not the test should be conducted under inert conditions or ambient conditions, although both feat that the manual implies that the test be conducted under ambient and the material does not reach the criteria necessary to be considered 4.3. conditions. When we follow these guidelines, very little gas is emitted from the catalyst Summary: As per the results from Saféty Consulting Engineers, and per my telephone neither 4.2 or 4.3. We do know that our material is 4.1. Would we correct conversation with Richard Tarr, we would be in compliance to classify our material as to follow the labs results and classify our material as 4.1, flammable solid, and not 4.2 or 4.37 Thanks in advance for your help. :.#

Page 307/13/2001 11:16 FAX 410 531 4440 WR GRACE 0903 Michael P. DeCicco W.R. Grace Polyolefin 531-4559 (PHONE) Catalyst Research and Development Michael. DeCicco@grace.com 531-4440 (FAX)#