ADCO Products, Inc. — Hazardous Materials Safety Interpretation

Page 1Or resportation JAN 3 0 2002 Washington, D.G. 20590 400 Seventh St., S.W. Daniel M. Dixon, Jr. Health, Safety and Environmental Ref. No. 01-0266 Manager ADCO Products, Inc. P. O. Box 457| Michigan Center, MI 49254 Dear Mr. Dixon: This is in response to your October 3, 2001 letter concerning assignment of a hazardous material to a specific packing group under the Hazardous Material Regulations (HMR: 49 CFR Parts 171- 180). Specitically, you ask how to properly reassign a flammable liquid adhesive from a Packing Group II to a Packing Group III when the liquid is too thick to complete the ISO 2431 (1984) viscosity test in § 173.121(b)(2)(i), preventing the comparison of its viscosity and flash point required in § 173.121(b)(1)(iv). I apologize for the delay in responding and any inconvenience this may have caused. You state that the adhesive has a flashpoint of 18°F and a boiling point of 185°F, does not separate when tested, does not contain any substances with a Division 6.1 (poison) or Class 8 (corrosive) hazard class, and is placed in six one-gallon inner packagings inside one outer packaging. You also state that the adhesive flows freely through an ISO standard cup until the cup is 50 to 75 percent full, then thickens while standing and does not flow freely for the remaining time required to complete the test. You further state that extrapolation of the test results yields flow times over 100 seconds through the 6 mm orifice. It is the shipper's responsibility to properly classify a hazardous material in accordance with § 173.22. This office does not perform that function. However, based on the information you provided, it is our opinion that the test results you have already completed for the adhesive fulfill the intent of the viscosity test prescribed in $ 173.121(b)(2)(i). No further calculations estimating product performance are necessary, and the adhesive meets the criteria to be assigned to Packing Group Ill as prescribed in § 173.121(b)(1). I hope this satisfies your request. Sincerely. Transportation Regulations Specialist Office of Hazardous Materials Standards 173.121 010266#

Page 2- Steven ADCO 913. Designing and Manufacturing Adhesive « Sealant Solutions Packing Group October 3, 2001 01-0266 Mr. Edward Mazzullo RSPA Office of Hazardous Materials Standards (DHM-10) 400 Seventh Street, SW U.S. Department of Transportation Washington, D.C. 20590 Subject: Viscosity Test-49 CFR 173.121 (b)(2)(i) Dear Mr. Mazzullo: assigning a packing group to a product that we produce and offer for shipment: We are requesting a written opinion concerning the following problem that we are experiencing with We currently manufacture a liquid adhesive product that is considered a Class 3 flammable liquid based set forth under 49 CFR 173.121 (b)(1). the condition for 49 CFR 173.121 (b)(1)(i). The product does not contain any substances with a We regularly conduct separation tests on the product and experience no separation; therefore, we meet primary or a subsidiary risk of Division 6.1 or Class 8, so we also meet the condition for 49 CFR 73.121 (b)(1)(ii). The product is packaged in one-gallon cans with six cans to each package makin final condition that must be met, 49 CFR 173.121 (b)(I)(iv), is a table comparing the viscosity of the le capacity of the packaging six gallons. This meets the conditions of 49 CFR 173.121 (b)(1)(iii). Th material with the flash point. This is where we experience our problem. As a measure of the viscosity of the material, 49 CFR 173.121 (b)(2)(i) references ISO-2431 be used. product to Packing Group III ADCO Products, Inc. 4401 Page Avenuc + PO Box 457 • Michigan Center, MI 49254 + (517) 764-0334 • (517) 764-6697 Fax#

Page 3ADCO Designing and Manufacturing Adbesive co Sealant Solutions On October 1, 2001, I spoke with Dr. Spencer Watson of the U.S. Department of Transportation Office of Hazardous Materials Technology about the problem that we are experiencing. His opinion was that the conditions set in 49 CFR 173.121 (b)(1)(iv). we appear to be meeting the intent of the viscosity test and that our product is viscous enough to meet email at daniel.dixon@adcocorp.com. I look forward to your opinion. If you have any further questions or concerns, please contact me by phone at 517-841-7207 or by Sincerely, Damel m. Sita, 3. Daniel M. Dixon, Jr. Health, Safety and Bavironmental Manager tanager 4401 Page Avenue + PO Box 457 • Michigan Center, MI 49254 • (517) 764-0334 • (517) 764-6697 Fax ADCO Products, Inc. SISO 90014 305-9000 REGISTERED#