Elite Consumer Products — Hazardous Materials Safety Interpretation

Page 1Washington, D.C. 20590 400 Seventh St., S.W. APR _ 8 2002 Mr. Mark Chevrier Director of Operations Reference No.: 02-0032 Elite Consumer Products 203 West Avenue Ludlow, MA 01056 Dear Mr. Chevrier: This is in response to your letter inquiring whether a 6.0 wt % sodium hypochlorite solution is subject to the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You submitted skin corrosivity test data for the material. In a telephone conversation with a member of my staff, you stated that the material is packaged in one gallon containers. Based on the data you provided, we agree that the 6% wt sodium hypochlorite solution is not corrosive to skin. However, without test data for corrosivity on metals (steel and/or aluminum), we are unable to make the determination that your material does not meet the definition in § 173.136 of a corrosive material (Class 8) under the HMR. Sincerely, Hothe Z. mthel Hattie L. Mitchell Chief, Regulatory Review and Reinvention Office of Hazardous Materials Standards 173.22 020032#

Page 2•" Corbin §/73.22 Elite Shippers Respassibili December 17, 2001 02-0032 Mr. Edward T. Mazzullo Director, Office of Hazardous Materials Standards 400 Seventh Street, SW U.S. DOT/ RSPA (DHM-10) Washington, DC 20590-0001 RE: Corrosivity of Sodium Hypochlorite Solution Dear Mr. Mazzullo: Per a recent discussion on December 17, 2001 with Mr. Ben Supko at the Hazardous Materials Information Center, it was his recommendation that Elite contact your office. Because of the listing in the DOT Hazardous Materials Table, inquiries have arisen from Elite's corrugated Sodium Hypochlorite. supplier as to the correct classifications (markings) that should appear on the cartons containing 6.0 wt % In previous letters from the Clorox Company and the KIK Corporation to your office on this subject, both companies presented data that determined that their products were not classified as corrosives in accordance with the definition specified in 49 CFR 173.136. Monitor Laboratories, Inc, Oak Park, IL. The results of that test (enclosed for your review) show that "In Elite submitted for testing, a sample of our 6.0 wt % Sodium Hypochlorite solution for corrosivity to Tox accordance with D.O.T. Guidelines, Federal Register, Volume 55, No. 246, Elite Consumer Products sample identified as 6 wt % Sodium Hypochlorite, is not a corrosive agent". issuing a letter confirming the department's conclusion that the Sodium Hypochlorite solution tested is not Upon your review and assuming that you agree with the conclusion of this test, Elite would appreciate your a corrosive material within the meaning of the current regulatory guidelines. Thank you for your attention to this matter. If you need additional information, please contact Richard Tata at (413) 589-1600 extension 303. Director of Operations, Elite Consumer Products CC: Richard Tata, Elite Consumer Products Enclosures: D.O.T. Corrosivity Test Results 203 West Avenue Elite Consumer Product: Nwwliteco.co ЛА 010 Fax: 413-589-7824 1-888-EliteCP#