MMA — Hazardous Materials Safety Interpretation

Page 1Transportatio S.Departmen Washington, D.C. 400 Seventh Street, S.W. 20590 OCT 1 1 2001 Mr. William J. Schuchman Ref. No. 01-0208 Executive Director MMA 10733 Big Bend Blyd. St. Louis, MO 63122-6027 Dear Mr. Schuchman: This is in response to your July 30, 2001 letter and subsequent conversations with Michael Johnsen of my staff concerning the determination of the packing group for a flammable liquid under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you asked for clarification of the criteria for inclusion of viscous Class 3 materials in Packing Group III provided in the table in § 173.121(b)(1)(iv) for viscous materials with a flash point under 23 degrees C (73 degrees F). Your example involves a viscous material that has a flow time of about 90 seconds through a 4 mm diameter jet and has a flash point of 70 degrees F. To determine if a material could be considered a Packing Group III material, the conditions in § 173.121(b)(1)(i) - (iv) must be met. Your question concerns interpreting the table in § 173.121(b)(1)(iv). You would first identify your flow time in column one through a jet diameter indicated in column two. Column three indicates the minimum flashpoint for your material to be considered a Packing Group III material. A material, with a flow time of 90 seconds through a 4 mm diameter jet, falls between the range in the second entry and requires a flash point above 10 degrees C (50 degrees F) to qualify for a Packing Group III material. Since the material in this example has a flash point of 70 degrees F, then it is considered a Packing Group III material if, in addition, the material also meets all other requirements of § 173.121(b)(I). I hope this satisfies your request. Sincerely, Suhan HaStig Delmer F. Billings Chief, Standards Development Office of Hazardous Materials Standards 010208#

Page 2Johnsen M 8173.121 (b) OSHI A Classification MG1 M 1988 Est. 01-0208 AN ENVIRONMENTAL & SAFETY/HEALTH COOPERATIVE Services July 30, 2001 *AIR POLLUTION *AIR PERMITS Room 8422 Mr. Ed Mazzullo *ANALYTICAL TESTING *ASSESSMENTS *ASBESTOS Office of Hazardous Materials Standards *BIOREMEDIATION *AUDITS RSPA U.S. Department of Transportation *BULK DISPOSAL *CITY/COUNTY EOP "CORRECTIVE ACTION PLANS "COMPLIANCE PROGRAMS 400 7'* St. SW Washington, DC 20590 *DESIGN *EIQ REPORTING "DISASTER PLANNING Dear Sir: *EMERGENCY RESPONSE *EMERGENCY PLANS •EMISSION MONITORING *ENGINEERING *EMPLOYEE TRAINING request a letter of interpretation. Several of the DOT associates that we spoke with recently suggested we write you and *ENVIRONMENTAL TESTING *ENVIRONMENTAL SAMPLING *FIRE PREVENTION We would appreciate clarification of 173.121(b) which allows for grouping viscous class *FREE INFORMATION *FREE OSHA/ACRA HOTLINE criteria and flash point/viscosity table must be met for this inclusion. The question we 3 packaging group Il materials in class 3 packaging group III. A solvent separation *HAZ WASTE MGT/ WALK THROUGH have concerns the table. *INDUSTRIAL HYGIENE DISPOSAL *INVESTIGATION The table provides ranges of viscosities, as measured by a flow cup, for various flash *LAB PACKS *LAND FARMING *LAB SERVICES question we have is may the viscosity exceed the range listed for a particular flash point points with the viscosity specification increasing as the flash point decreases. The *LEAKING TANK MGT *LIAISON (LUST MGT) of 90 seconds in the ISO cup with a 4 mm jet would meet the viscosity criteria even range? It seems logical to us that a material with a flash point of 70 degrees F and a flow *OSHA MEDIATION *NEWSLETTER though the table shows a flow time range of 20 to 60 seconds for flash points above 62.6 *PERMITS *OSHA PROGRAMS *PHASE *PHASE tI It is believed that the viscosity ranges are inclusive for materials with flash points at or *PROJECT DESIGNS *SAFETY PROGRAMS *PUBLIC RELATIONS above those lisied in the table. Thus in the example above all of the viscosity ranges •SARA SIl/FORM R/ apply since a 70 degree F flash point is above all of the flash point ranges indicated. *SITE CHARACTERIZATION TIER IS Otherwise lower flash point materials with the same viscosity as the example above *SOLID WASTE MGT and would he eligible forGil)It would not seem logical that a lower flash point could meet the criteria, e. g, 20 seconds with a 4 mm jet a flash point of 60 degrees F, *SPECIAL WASTE MGT/ *SPCCP *SPILL CONTROL DISPOSAL material would be eligible over a higher flash point material with the same viscosity. *TECHNOLOGY UPGRADES *STORM WATER COMPLIANCE We would greatly appreciate your comments. •TRAINER PROGRAMS *TIER I "24 HR. EMERGENCY Sincerely, "UST MGT RESPONSE HOTLINE *UST TANK CLOSURES *VIOLATION MEDIATION *WASTE MINIMIZATION *WASTEWATER SAMPLING William J. Schuchman Executive Director 10733 BIG BEND BLVD, • ST. LOUIS, MO 63122-6027 • 314-966-1006 • FAX 314-966-4176 CORPUS CHRISTI, TEXAS • 512-887-7471#