{"operation":"document","citation":"01-0266","title":"ADCO Products, Inc. — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2002-01-30","effective_on":null,"summary":"01-0266 response to ADCO Products, Inc. concerning 173.121.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-01-0266.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-01-0266.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-01-0266","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2001/010266.pdf","body":"<<<PAGE 1>>>\n\nOr resportation\nJAN 3 0 2002\nWashington, D.G. 20590\n400 Seventh St., S.W.\nDaniel M. Dixon, Jr.\nHealth, Safety and Environmental\nRef. No. 01-0266\nManager\nADCO Products, Inc.\nP. O. Box 457|\nMichigan Center, MI 49254\nDear Mr. Dixon:\nThis is in response to your October 3, 2001 letter concerning assignment of a hazardous material\nto a specific packing group under the Hazardous Material Regulations (HMR: 49 CFR Parts 171-\n180). Specitically, you ask how to properly reassign a flammable liquid adhesive from a Packing\nGroup II to a Packing Group III when the liquid is too thick to complete the ISO 2431 (1984)\nviscosity test in § 173.121(b)(2)(i), preventing the comparison of its viscosity and flash point\nrequired in § 173.121(b)(1)(iv). I apologize for the delay in responding and any inconvenience\nthis may have caused.\nYou state that the adhesive has a flashpoint of 18°F and a boiling point of 185°F, does not\nseparate when tested, does not contain any substances with a Division 6.1 (poison) or Class 8\n(corrosive) hazard class, and is placed in six one-gallon inner packagings inside one outer\npackaging. You also state that the adhesive flows freely through an ISO standard cup until the\ncup is 50 to 75 percent full, then thickens while standing and does not flow freely for the\nremaining time required to complete the test. You further state that extrapolation of the test\nresults yields flow times over 100 seconds through the 6 mm orifice.\nIt is the shipper's responsibility to properly classify a hazardous material in accordance with\n§ 173.22. This office does not perform that function. However, based on the information you\nprovided, it is our opinion that the test results you have already completed for the adhesive fulfill\nthe intent of the viscosity test prescribed in $ 173.121(b)(2)(i). No further calculations\nestimating product performance are necessary, and the adhesive meets the criteria to be assigned\nto Packing Group Ill as prescribed in § 173.121(b)(1).\nI hope this satisfies your request.\nSincerely.\nTransportation Regulations Specialist\nOffice of Hazardous Materials Standards\n173.121\n010266\n\n<<<PAGE 2>>>\n\n- Steven\nADCO\n913.\nDesigning and Manufacturing Adhesive « Sealant Solutions\nPacking Group\nOctober 3, 2001\n01-0266\nMr. Edward Mazzullo\nRSPA Office of Hazardous Materials Standards (DHM-10)\n400 Seventh Street, SW\nU.S. Department of Transportation\nWashington, D.C. 20590\nSubject: Viscosity Test-49 CFR 173.121 (b)(2)(i)\nDear Mr. Mazzullo:\nassigning a packing group to a product that we produce and offer for shipment:\nWe are requesting a written opinion concerning the following problem that we are experiencing with\nWe currently manufacture a liquid adhesive product that is considered a Class 3 flammable liquid based\nset forth under 49 CFR 173.121 (b)(1).\nthe condition for 49 CFR 173.121 (b)(1)(i). The product does not contain any substances with a\nWe regularly conduct separation tests on the product and experience no separation; therefore, we meet\nprimary or a subsidiary risk of Division 6.1 or Class 8, so we also meet the condition for 49 CFR\n73.121 (b)(1)(ii). The product is packaged in one-gallon cans with six cans to each package makin\nfinal condition that must be met, 49 CFR 173.121 (b)(I)(iv), is a table comparing the viscosity of the\nle capacity of the packaging six gallons. This meets the conditions of 49 CFR 173.121 (b)(1)(iii). Th\nmaterial with the flash point. This is where we experience our problem.\nAs a measure of the viscosity of the material, 49 CFR 173.121 (b)(2)(i) references ISO-2431 be used.\nproduct to Packing Group III\nADCO Products, Inc.\n4401 Page Avenuc + PO Box 457 • Michigan Center, MI 49254 + (517) 764-0334 • (517) 764-6697 Fax\n\n<<<PAGE 3>>>\n\nADCO\nDesigning and Manufacturing Adbesive co Sealant Solutions\nOn October 1, 2001, I spoke with Dr. Spencer Watson of the U.S. Department of Transportation Office\nof Hazardous Materials Technology about the problem that we are experiencing. His opinion was that\nthe conditions set in 49 CFR 173.121 (b)(1)(iv).\nwe appear to be meeting the intent of the viscosity test and that our product is viscous enough to meet\nemail at daniel.dixon@adcocorp.com. I look forward to your opinion.\nIf you have any further questions or concerns, please contact me by phone at 517-841-7207 or by\nSincerely,\nDamel m. Sita, 3.\nDaniel M. Dixon, Jr.\nHealth, Safety and Bavironmental Manager\ntanager\n4401 Page Avenue + PO Box 457 • Michigan Center, MI 49254 • (517) 764-0334 • (517) 764-6697 Fax\nADCO Products, Inc.\nSISO 90014\n305-9000\nREGISTERED","truncated":false,"body_characters":4565}