{"operation":"document","citation":"01-0235","title":"Alliant Techsystems Inc. — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2002-02-06","effective_on":null,"summary":"01-0235 response to Alliant Techsystems Inc. concerning 173.136.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-01-0235.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-01-0235.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-01-0235","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2001/010235.pdf","body":"<<<PAGE 1>>>\n\n•\n•\nU.S. Department\nof Transportation\n400 Seventh Street, S.W.\nWashington, D.C.\n20590\ndiministration\nsearch an\nFEB - 6 2002\nMr. Christopher J. Widman\nAlliant Techsystems Inc.\nRef; No. 01-0235\nTwin Cities Arsenal\nNew Briehton. MN 55112\nDear Mr. Widman:\nThis responds to your letter requesting an exception to transport waste water samples as \"Not\nRegulated\" under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You\n8 (corrosive) materials.\nAlliant Techsystems, Inc., currently transports \"Waste Water Samples,\" preserved with various\namounts and concentrations of Class 8 (corrosive) materials. These materials are shipped as\nlimited quantities under the exception for corrosive materials in § 173.154(a)(2), and are not\neligible for the small quantities exception in § 173.4. In a subsequent telephone conversation\nwith Helen Engrum, a member of my staff, you clarified that you are requesting an exception\nfrom the HMR for waste water samples: 1) In 40 ml, 500 ml, and 1000 ml inner containers; 2) In\na volume of 1.0% concentration of preservative; and 3) With a pH range from 0 to 12. You\nasked that the materials listed below be excepted from the HMR. The materials are as follows:\nHazardous Materials\nSize of Inner Containers\nof 1.0% by weight or less\nHydrochloric acid (HC1), in water at concentrations\n40 ml, 500 ml, and 1000ml\nNitric acid (HNO,) in water at concentrations\n500 ml and 1000ml\nof 1.0% by weight or less\nSulfuric acid (H,SO,) in water at concentrations\n500 ml and 1000ml\nof 1.0% by weight or less\nSodium hydroxide (NaOH) in water at concentrations\n500 ml and 1000ml\nof 1.0% by weight or less\n173.136\n010235\n\n<<<PAGE 2>>>\n\nYou did not provide sufficient information (e.g., corrosivity data) to support an exception from\nregulation under the FiMIR. Based on the information you provided, it is our opinion that the\npreservatives in water solutions in the concentrations listed above meet the definition of Class\n(corrosive) materials. In addition, waste water samples that have a pH range of 2 or less or 1l.5 or\ngreater are classified as a Class 8 (corrosive) in accordance with \"OECD Guideline For Testing\nabove, containing the various concentrations of corrosive materials, are subject to the HMR and\not Chemicals (See §§ 173.136 and 173.137). Therefore, the waste water samples indicated\nmay not be shipped \"Not Regulated\" for purposes of transportation.\nI hope this satisfies your inquiry.\nSincerely,\nDelmer F. Billings\nChief, Standards Development\nOffice of Hazardous Materials Standards\n\n<<<PAGE 3>>>\n\n30-2001\n10:39\nALLIANT TECHSYSTEMS\nP.02\nTwin Cities Arsenal\nAlliant Techsystems Inc.\nTel\n(651)\n639-3334\n30 August 2001\nNew Brighton, MN 55112\nFax (651)\n639-3341\nOffice of Hazardous Materials Standards\nUS Department of Transportation\nKngram,\n2173.136\nMr. Edward Mazzullo - DHM-10\n400 Seventh Street SW\nWashington DC 20590\nExcepting ClassiFication\nDear Mr.\n01 -0235\nAlliantTechsystems (ATK) is requesting an exception to transport Waste Water\nSamples as \"Not Regulated\" per 49CFR. It has been verified that the DOT has\noffered relief from 49CFR for transporting waste water samples to two (2) other\nsamples in the country. ATK is seeking relief from 49CFR relative to packaging,\ncompanies. ATK is aware that there are many transporters of waste water\nmarking, and labeling our waste water samples as Class 8, Corrosive Materials.\nin addition, ATK is requesting that we be authorized to transport these waste\n(corrosives) then what was previously approved.\nwater samples in larger containers, with a higher ratio of preservatives\nBACKGROUND\nATK currently transports Waste Water Samples preserved with a very small\nthese waster water samples as Class 8, Corrosives.\nvolume of various Class 8, Corrosive materials. ATK is presently transporting\nmaterials who have been given exception from 49CFR.\nATK has obtained DOT documentation issued to other transporters of identical\nATK wishes to also obtain exception (transport as not regulated) for the same\nmaterials. We also wish to notify your office of our intent to receive authority to\ntransport as not regulated in containers larger then previously approved, and\nalso containing higher volume of various preservatives.\n\n<<<PAGE 4>>>\n\n18-2001\n10:39\nALLIANT TECHSYSTEMS\nP.03\ntwo (2) transporters of waste water samples.\nAttachment A contains correspondences between your office and the following\nUS DOT letter dated November 7*, 2000\nTO: National Oceanic & Atmospheric Administration\nQAR Laboratories\nP/MEL\nSeattle Washington\nUS DOT letter dated December 13\", 1993\nTo: GTEL Environmental Laboratories, Inc.\nWichita Kansas\n49CFR parts 171-180 for transporting the following:\nAs can be seen in these approvals, the DOT authorized exception to HMR:\nHC1 in water with concentrations of 0.04% by weight, or less\nHgC1, in water in concentrations of 0.004% by weight or less.\nHNO, in water at concentrations of 0.15% by weight or less.\nNaOH in water at concentrations of 0.080% by weight or less.\nH,SO, in water at concentrations of 0.35% by weight or less\nH,PO, in water at concentrations yielding a pH range between 4 and 2.\nATK's REQUEST\nATK requests your office authorizes exception from 49CFR parts 171-180 to\nATK for the same various Class 8 corrosive materials, with the following\nadditions.\n1) Increasing the maximum size of the containers from 500-ml to 1000-ml ..\n2) Authorize an increase in the volume of preservatives used to a 1.0%\nmaximum for all candidates.\n3) Offer relief from sampies with a now ph range from 4 to 2, to a ph range\nfróm 0 to 12.","truncated":false,"body_characters":5557}