{"operation":"document","citation":"02-0092","title":"SENSIDYNE — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2003-02-13","effective_on":null,"summary":"02-0092 response to SENSIDYNE concerning 173.4.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-02-0092.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-02-0092.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-02-0092","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2002/020092.pdf","body":"<<<PAGE 1>>>\n\nof Transportatior\nJ.S. Departmeni\n400 Seventh St., S.W.\nResearch and\nWashington, D.C. 20590\nSpecial Programs\ndministration\nFEB | 3 2003\nMr. Ron Roberson\nRef. No.: 02-0092\nCorporate Industrial Hygienist & Technical Manage\nSENSIDYNE\n16333 Bay Vista Drive\nClearwater, FL 3376088\nDear Mr. Roberson:\nThis responds to your letter regarding the small quantity exceptions under the Hazardous Materials\nRegulations (HMR: 49 CFR Parts 171-180), as they apply \"smoke tubes\" sold by your company. We\napologize for the delay in responding and hope it has not caused any inconvenience.\nAccording to your letter, the smoke tubes are used to track air currents in ventilation studies and to test\nrespirators for proper fit in accordance with OSHA standards for irritant fume respirator fit test\nprotocol. Each smoke tube consists of a pencil-sized sealed glass tube filled with pumice granules\ncoated with approximately one gram per tube of \"Stannic chloride, anhydrous, 8, UN 1827, II.\" The\ntubes are activated by breaking off the ends and pushing ambient air through with a small rubber bulb or\nmotorized pump. Moisture in the air reacts with the stannic chloride and produces the smoke. The\nsmoke tubes are sold in a box of ten tubes.\nA material described as \"Stannic chloride, anhydrous, 8, UN 1827, IN\" may be transported under the\nsmall quantity exception if it meets the quantity limits and packaging requirements in § 173.4, and is not\nforbidden under § 173.21. Based on the description of the \"smoke tubes\".\nmay be transported under the small quantity exception provided the quantity of the Class 8 (corrosive)\n, it is our opinion that they\nmaterial in the inner packaging (i.e., glass tube) is less than 30 grams (1 ounce) and all other provisions\nof § 173.4 are met. A package shipped in accordance with the small quantity exceptions in § 173.4 is\nnot subject to any other requirements of the HMR, including labeling. The \"smoke tubes\" may also be\nshipped under the limited quantity exceptions for corrosive materials in § 173.154, which excepts such\npackages from the labeling requirements, unless offered or intended for transportation by aircraft.\nI hope this satisfies your inquiry. If we can be of further assistance, please contact us.\nSincerely,\nDelmer F. Billings\nChief, Standards Development\nOffice of Hazardous Materials Standards\n113.4\n020092\n\n<<<PAGE 2>>>\n\nEngrum\n5173.4\nSENSIDYNE: Small Quantity\nxceptions\n16333 BAY VISTA DRIVE, CLEARWATER, FLORIDA 33760 USA 02-0092\nTEL: 800-451-9444, (727) 530-3602 (FL)\nFAX: (727) 539-0550\nCOMPANY: US DOT Ofeof Haz Mat Safety FROM:\nRon Roberson\nFAX:\n202-366-3012\nDATE:\nMarch 25, 2002\nATIN:\nDelmer Billings.\nPAGES:\n1\nOF.\n- 1\nSUBJECT:\nVentilation Smoke Tube Shipping\nMESSAGE\nDear Mr. Billings:\nMy company sells smoke tubes that are used to track air currents in ventilation studies\nand also to test respirators for proper fit per the OSHA irritant fume respirator fit test\nprotocol. Each smoke tube consists of a pencil-sized sealed glass tube filled with pumice\nof ten tubes, so ten tubes are the minimum number we would ship at one time. To use the\ngranules coated with about one gram per tube of stannic chloride. They are sold in a box\nrubes, they are activated by breaking off the ends and pushing ambient air through with a\nsmall rubber bulb or motorized pump. Moisture in the air reacts with the stannic chloride\nWe began shipping these tubes in the fall of 1983 believing that they met a small\ntubes was broken in transport. The broken tubes were activated by the sirrounding air\nquantity labeling exemption for stannic chloride. Within the first year or two a package of\nwhich caused them to produce smoke. The smoking package prompted a DOT official to\ninstruct us to label the packages as hazardous material. We were told that because the\nSine ta time (o, mid 15803) at be lin te smoke de in as it.:.\n1827 and corrosive, and we have been paying the hazardous shipment fees on every\nshipment.\nazardous labeling. We share a common distributor who is questioning why our freigh\nA competitor of ours ships a similar stannic chloride smoke tube product without the\nharges include the hazardous fee and the competitor's do not. The competitor claims in\nform letter to customers that the tubes meet a small quantity labeling exemption under 49\nCFR Part 173.4.\n100 D\n\n<<<PAGE 3>>>\n\nIs the competitor's claim valid? Do the small. quantity descriptions in 173.4 apply to\nSor abeing that does appry Can you est us if ten is thous another sin a uly try break.\nfor our smoke tube packages? Your consideration of this matter is much appreciated, and\nwe would like to receive a letter of interpretation for our files. Thank you for your kind\ncooperation.\nSincerely,\nRon Roberan\nRon Roberson\nCorporate Industrial Hygienist\n& Technical Manager\n200 7\nONE ENDORSNES\n09906894LXE","truncated":false,"body_characters":4826}