ECD Engineering — Hazardous Materials Safety Interpretation

Page 1400 Seventh St., S.W Washington, D.C. 20590 Special Programs Research and JAN 4 2002 Administration Ms. Karen Schaaf ECD Engineering Reference No.: 01-0319 5200 Blazer Parkway Dublin, Ohio 43017 Dear Ms. Schaaf: This is it response to your inquiry concerning the pressure rating required for plastic drums used to transport 30% ammonium hydroxide under the Hazardous Materials Regulation (HMR; 49 CFR Parts 171-180). You submitted a Material Safety Data Sheet and a vapor pressure curve with your inquiry. Under $ 173.22, it is the shipper's responsibility to determine that the packaging or container is assembled, and marked in accordance with part 178. However, based on the information you an authorized packaging, including part 173 requirements, and that it has been manufactured, provided, it is the opinion of this office that a hydrostatic test pressure of at least 300 kPa is required for the plastic drums. I hope this information is helpful. Sincerely, Transportation Regulations Specialist Office of Hazardous Materials Standards 010319 173.22#

Page 2:. DEC.14.2001 8:09AM ASHLAND CHEM ECD 614 790 4213 NO. 861 P.1/12 Corbin ECD Engineering Ashland § 173,24 5200 Blazer Parkway Dublin, Ohio 43017 Genon Pecke mAX Number: 614-790-4213 01-0314 FAX TRANSMITTAL FORM DATE: December 13, 2001 TO: Diroctor of the Office of Hazardous Materials Standard FAX NUMBER: 202-366-3012 FROM: Karen Schaaf PHONE NUMBER: 614-790-6440 NUMBER OF PAGES SENT (including cover): 12 COMMENTS: We would like to know what pressure rating is required to ship 30% ammonium hydroxide in drums. We are tying to clarify apparently conflicting information we have received from drum suppliers. I have attached an MSDS and a vapor pressur urve. Plense provide a written reply at your earliest convenience If you need anything else, please let me know. Thanks, Karen Schaaf EST ENR Lass Saved: 12/13/01 9:13 AM#