Dr. Arnel D. Potte — Hazardous Materials Safety Interpretation

Page 1Washington, S.C. 2052 2059 Special Programs Administration MAY 8 2002 Dr. Arnel D. Potter Ref. No. 02-0037 490 S Waukegan Rd Lake Forest, Il 60045 Dear Dr. Potter: This is in response to your January 31, 2002 letter requesting clarification on the correct proper shipping name for your material as specified in the Hazardous Materials Regulations (HIMR; 49 CFR Parts 171-180). Specifically, you ask if the proper shipping name for your material should be "Oxidizing solid, corrosive, n.o.s." or "Toxic solids, oxidizing, n.o.s." Under § 173.22, it is the shipper's responsibility to properly class and describe their material in accordance with parts 172 and 173 of the HMR. This Office does not perform that function. A material not specifically listed in the § 172.101 Hazardous Materials Table (§ 172.101 HMT) and meets the definition for Division 5.1, PG II and Class 8, PG III must be described as "Oxidizing solid, corrosive, n.o.s., 5.1, 8, UN3085, II." If the material is not specifically listed in the § 172.101 HMT and meets the definition for Class 6.1, PG I for dermal toxicity and Division 5.1 PG II or III then the material must be described as "Toxic solids, oxidizing, n.o.s., 6.1, 5.1, UN3086, I." I hope this satisfies your request. Sincerely, Office of Hazardous Materials Standards (72,10) 020037#

Page 2KAH 3 / 2 : 10* - Proper Shipping Name 02-0037 Thursday, January 31, 2002 Director Office of Hazardous Material Standards Mr. Edward Mazzullo DA M-10 Research and Special gressive Administration Agency 400 7th Street S.W. Subject: Correct name for Chromic Acid solid mixtures Washington D.C. 20590-0001 The correct name is Chromic Acid ,solid. The hazard class is PG PG is II. Tabel codes are Foe Chromic acid solid: For a solid mixture containing 50-80% chromic acid according to the tables and 5.1,8. discussions with Mr. Arthur Pollack, Charles Betts and Ailene, the correct name for the Chromic acid mixture would be : Oxidizing solid, corrosive, n.o.s. UN 3085, 11, 5.1,8.( contains Chronic Acid solid) A client is insisting that chromic acid mixtures according to DOT should be shipped as toxic solids with a UN 3086 number. This is given for Toxic solias,oxidizing.n.o.s., 6.1, UN3086, 1,6.1,5.1 As pure Chromic acid has a PG of II in the tables, has the DOT derermined that chromic acid mixtures are more toxic than diluted chromic acid in solid form? Any help in the proper name for chromic acid solid mixtres would he greatiy appreciated in writing and in as short of time that you would be able to help on this subject. Sincerely, Arnel D. Potter Fax 847-234-1380 Posasta OBETTEZLES 80:90 [00z/|#

Page 3Mr. Camoron As per our discussion today in reference to Chromic Acid, solid mixtures: Chromic acid, solid Hazard Class is 5.1, UN1463, PG I%, Label codes 5.1,8 Oxidizing solid, corrosive, n.o.s. Hazard class 5.1 , UN3085 , PG II, Label codes 5.1,2 1 chromic acid solid mixture if the oxidizer and corrosive properties are not greatly reduced would be In the Precedence of Hazard Table 173.28: The order of classes would be 5.1, 8 and then 6.1 Il. The 5.1 is the primary, and 8 secondary. It would not be logical or acceptable to ship the Chromic acid mixture under Hazard class 6.1, PG II as the table indicates that 5.1, 8 would be the acceptable label code. For Chromic acid solution (containing water and chromic acid): According to 173.132 , this solution should also be classed as a class 6, Division 6.1 Chromic acid solution, Hazard class is 8, UN1755, PG II and Label code is 8. As 8 is the primary class, should the secondary class be 6.1, PG II and the Label codes be 8,6.1 according to your tables? Corrosive liquids, toxic, r.o.s., Hazard class 8, UN2922 , PG II, Label codes 8,6.1 or For chromic acid solutions containing components other than warer be then classified as : Thank you in helping to clarify the labelling. Corrosive liquids, toxic, n.o.s., Hazard class 8,6.1, UN2922, PG II, Labei codes 8,6.1 Sincerely, Dr. Arnel D. Potter Telephone 8472341282 Fax 8472341380 IB 354d 10:00 2002020#