Quay Equestrian Limited — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department 400 Seventh St., S.W. Washington, D.C. 20590 Research and Administrations MAY 17 2002 Mr. Andrew Stockford Ref. No. 01-0303 Managing Director Quay Equestrian Limited St. George's Quay Lancaster, England LA1 5QJ Dear Mr. Stockford: This is in response to your communications concerning the transportation of your company's soap product as a consumer commodity under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask whether your product, transported as "Consumer commodity, ORM-D," is packaged, marked and labeled in accordance with the HMR for transportation by highway. n.o.s. (contains Methylated spirits), 3, UN1987, PG III." According to Mr. John Nunn of your The material safety data sheet you provided describes the soap product as "Flammable liquid, company, the packagings are shipped into the United States, meet the definition in § 171.8 for a consumer commodity, and are repackaged for shipment as follows: Inner packaging: a non-specification, polyethylene bottle 500 ml, 750 ml, or 2.5 gallons in size equipped with a pump dispenser (depending on the size, as many as 12 inner packagings will be placed in one outer packaging) Outer packaging: a strong non-specification fiberboard box Marking: one side or end with "Consumer commodity, ORM-D" Labeling: hone Based on the information you provided, when your product is being repackaged for transportation in accordance with the HMR, the 500 ml and 750 ml inner packagings may be transported as «Consumer commodity, ORM-D" provided each strong outer packaging does not exceed 66 Ibs. You are correct in your understanding that the packagings must be marked on at least one side or end with "Consumer commodity, ORM-D" and that the packagings are excepted from the labeling requirements. In addition, shipments of ORM-D materials are not subject to the shipping paper requirements of the HMR unless the material meets the definition of a hazardous substance, hazardous waste or marine pollutant, or is offered for transportation by aircraft. 113 • 010303#

Page 2With regard to your 2.5 gallon inner packagings, as provided in § 173.150, PG III inner packagings must not exceed 5.0 L (1.3 gallons) net capacity each to meet the limited quantity exceptions. The 2.5 gallon inner packagings, therefore, may not be transported as "Consumer commodity, ORM-D." Appropriate shipping descriptions for the 2.5 gallon inner packagings (see § 172.101(c)(12)(ii)) would be: "Flammable liquid, n.o.s. (Alcohol), 3, UN1993, PG III," "Flammable liquid, n.o.s. (Ethanol, Methanol), 3, UN1993, PG III," "Alcohols, n.o.s. (Alcohol), 3, UN1987, PG III," or "Alcohols, n.o.s. (Ethanol, Methanol), 3, UN1987, PG III." The 2.5 gallon inner packagings must be packaged in accordance with § 173.203 as designated n Column (7) for the above shipping descriptions. These packagings must be marked with th roper shipping name and ID number, and display the FLAMMABLE LIOUID label I hope this information is helpful. Sincerely, tatter z mitchell Hattie L. Mitchell Chief, Regulatory Review and Reinvention Office of Hazardous Materials Standards cc: Mr. John Nunn Nunn Finer Products 2825 Northeast Road Northeast, MD 21917 2#

Page 319/11/2081 17:05 01524-32888 QUAY. EQUESTRIAN LTD HAGE 01/0/ Edmonson 8/13.150 extephons QUAY EQUESTRIÄN St George's Quay, Lancaster, LA1 5QJ; England QUAY EQUESTRIAN LIMITED Tel: +44 (0) 1524 381821 Fax: +44 (0) 1524 32080 Email: horses@quayequestrian.com Website: www.quayequestrian.com DATE 19 November 2001 NO OF PAGES (inc this one) 7 FOR THE ATTENTION OF Eileen Edmondson / Transportation Regulations Specialist PLEASE REPLY TO Andrew Stockford OUR NUMBER 0044 1524 32080 YOUR NUMBER 001 202 366 3012 Dear Eileen urther to our recent telephone conversation, I enclose a copy of our original fax dated 21 ugust 2001. You requested further information detailed in an email of 21 September In answer to these questions 1. The inclui of alohol. NO is an error. The description should us be " Consumer 2. Attached 3. We no longer require classification on this product. 4. As above . The Belvoir Spray Soap is in a pump dispenser. It means the requirements of 49 CFF 73.150. It is class 3, packing group lil. it is packed in containers of 500ml + 750ml eac enclosed in a strong corrugated outer. 6. As 3 SCARR & DAY 2 MARTIN 1 Ranvet A ALLORET -0SH DUCT OF STEN BIT DAY SON & HEWITT'#

Page 419/11/2001 17:05 01524-32080 •QUAY EUUESIKLAN LIN THUE UGIUI • 7. Products are shipped to the US in accordance with IMDG / IATA regulations in corrugated aware our customer is shipping products according to US domestic regulazions. AlI outer, which are then palletised and stretch wrapped. Once in the US so far as we are products will be dispatched at least in corrugated outers. 8. The product was incorrectly labelled. relevant regulations. Can you please confirm the correct labelling of this product to ensure we comply with the Yours sincerely amsofard Andrew Stockford Managing Director BETTEDAY: MARKAY Ranvet .05H» DAY SON & HEWITT#

Page 519/11/2001 17:05 91524-32080 QUAY EQUESTRIAN LTD PAGE DJ/01 QUAY EQUESTRIAN St George's Quay, Lancaster, LA1 5QJ, England QUAY EQUESTRIAN LIMITED Tel: +44 (0) 1524 381821 Fax: +44 (0) 1524 32080 Email: horses@quayequestrian.com Website: www.quayequestrian.com DATE 2B August 2001 NO OF PAGES (inc this one) FOR THE ATTENTION OF Edward Mazzullo/US Hazardous Materials Info Centre PLEASE REPLY TO Roger Donallon OUR NUMBER 00441524 32080 YOUR NUMBER 001 202 366 3012 Re: Shipment of flammable liquids by road. Dear Edward, Our company ships a flammable liquid to the US. One of our customers is having difficulty shipping is correct and would be grateful if you would confirm in writing that they can legally ship the the product by road via UPS. We just wish to check that our interpretation of the requirements product by road via UPS under the following circumstances. Product Details. UN number 1987 Class 3 hazardous flammable liquid containing alcohol N.O.S. - Packaging group 3. Case quantity 12. Container size 500ml. • Packaging format trigger bottles labelled and packaged for consumer use. Our understanding of the requirements. limited quantity. Because of the 500ml content, the product is excepted from labelling requirements by virtue of each case "Consumer Commodity Alcohol N.O.S. ORM-D. We are able to re-classify the product as a consumer commodity by marking one side or end of SCARE, DAY ANARTE Ranvet 05H DAY SON & HEWITT ...#

Page 619/11/2001 17:05 01524-32080 QUAY EUUESIKLAN LID THUE 0410! Provided that each case is marked in this way in a black rectangle which 0.25 inches larger than the edge of the print, the product can be shipped legally by road via UPS without any additional labelling or road freight papers. I would again be grateful if you could confirm by fax or E-mail to the above number for my attention that this is the case. I look forward to hearing from you: Best Regards, rich-ine Sales Director. Roger Donallon#

Page 719/11/2001 17:05 01524-32080 LUAY EWUESIKIAN LIU THIC DOIUI Product Safety Data Sheet Carr & Day & Martin Ltd 1 identification of Preparation and the Supplier Supplier. Trade Name: Belvair Spray Soap Tel: 01524 381821 Carr & Day & Martin Ltd, St George's Quay, Lancaster LA1 5QJ. Hazard details are held by the Natlonal Polsons Service Fax: 01524 32080 Information on Ingredients Hazardous ingredients: Material of Component % Range (active) Symbol Risk Phrases 3 Hazards Identification Methylated Spirts 20-25%w/ Flammable. Not regarded as a health hazard under current legislation. First Aid Measures Eyes. General: NOTE! Keep affected person away from heat, sparks and flames. Immediately irrigate with eyewash solution or clean water, holding the eyelids Skin: apart for at least 10 minutes. Obtain immediate attention. Remove contaminated clothing. Wash off immediately with water. Obtain ingestion: water to drink and obtain urgent medical attention, showing the label. Do not induce vomiting. Wash out mouth with water, then give plenty of milk or Inhalation: Remove patient from exposure. Obtain medical attention if ill effects occur. Perform artificial respiration if breathing has stopped. Fire Fighting: Protective Equipment for Alcohol resistant foam carbon dioxide, sand, dry chemicals, dolomite etc. Cool containers exposed to flames with water until well after the fire is out. Keep run-off water out of sewers and water sources. Dike for water control. reduce vapours. If risk of water pollution oocurs, notify appropriate authorities. Move container from fire area if it can be done without risk. Use water spray to Hazands: Unusual fire & explosion If risk of water pollution occurs, notify appropriate authorities. to source ofignition and flash. Vapours may ignite. May form explosive or toxic mixtures with air. May travel considerable distance 6 Accidental Release Measures Spillage cleanup methods: Ventilate well. Remove ignition sources. Do not allow chemical to enter confined way from combustible materials. Inform authorties if large amounts a volved. Dilute with copious amounts of wate 7 Handling and Storage Handling: pen flame. Ventilate well, avoid breathing vapours. Use approved respirator i void spilling and contact with skin and eyes. Keep away from heat, sparks ant Storage: contamination is above accepted level. oxidising agents, heat and flames. Store in a cool place in the original container, tightly closed. Keep away from Eye Protection: Skin Protection: See rei can end read a range in ornat. Occupational Exposure Limits: Hazardous Ingredients) ppm LTEL 8hr TWA STEL (15 mins) Methylated Spirits 1000 ppm mg/m3 *OES Type GAS#

Page 819/11/2801 17:05 01524-32080 WUHY EUULSIKIHY LID 9 Physical and Chemical Properties Appearance/Colour: Liquid. Auto ignition Temp (°C): No data. -Odour: Boiling Pt (°C): Acetone, Ketone. Vapour Pressure @ 20°C: No data. 94 Relative Density @ 20°C: No data. Melting Pt (°C): No data Flash P1 (°C): 23°C. (Sh CC) 10 Stabilly and Reactivity Materials to Avoid: Conditions to Avoid: Heat, sparks, fame. Hazerdous Decomposition Strong oxidising agents. Products: Toxic gases/vapours/fumes of: CO Carbon Monoxide. 1 Tas or apol i matul on prolonged exposure or in high concentration. NS depressant. Narcotic effect. Skin Contact: Irritating to eyes and mucous membranes. May cause irritation or mild dermatitis. Defatting, drying and cracking of skin. Inhalation: ngestion: May be hamful by inhalation and may cause respiratory distress. May cause severe intemal injury. 12 Ecological information Taxicity: Biodegradability: Biodegradable. Treatment: Effect on Effluent No data. At levels found in effluent, will have no adverse effect on biological Mobitity: Distribution Bioaccumulation is unlikely. Unlikely to build up in sediment or sewage sludge. 13 Disposal Product: Dispose of in accordance with local or national regulations in licensed special Packages: landfill or incineration as appropriate. Containers should be cleaned by appropriate methods and disposed of by 14 Transport Infarmation Classification of Transport: Flammable • ADR/RID Item No: ADE/RID Class: IMDG Class: IMDG Packaging Group: 5 Regulatory Information Risk Phrases: EC Classification R10: Flammable Flammable. S23A: Do not breathe gas/fumes/vapour/spray. Safety Phrases: S2: Keep out of reach of children. 346: If swallowed seek medical advice immediately and show this containe S51: Use only in well ventilated areas 16 Other Information label. This data sheet was prepared in accordance with Directive 93/112/EC. Date of preparation 24 January 2001.#