3M Company — Hazardous Materials Safety Interpretation

Page 1JS. Department of Transportation Washingion, S.C. 20590 Washington, D.C search an SEP 1 9 2002 Mr. Ray Duzynski 3M Company Ref. No. 02-0125 3M Center, Bldg. 225-5N-07 St. Paul. MN 55144-1000 Dear Mr. Duzynski: This is in response to your inquiry dated April 3, 2002 regarding the selection of a proper shipping name. Specifically, you ask that if a material contains a material that does not contribute to the primary or subsidiary hazard class of the material, does it need to be included in the determination of the proper shipping name. If a material, that in certain concentrations meets the definition of a hazardous material, is being shipped in a concentration that the mixture no longer meets the hazard class associated with the material, the material is not a hazardous material for purposes of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Section 172.101(c)(10)(i) states that a mixture or solution not identified specifically by name, comprised of a hazardous material identified in the Hazardous Materials Table (HMT) by technical name and non-hazardous material, shall be described using the proper shipping name of the hazardous material and the qualifying word identified by technical name in the HMT and a non-hazardous material that does not contribute to "mixture" or solution, as appropriate, Therefore, a mixture comprised of a hazardous material the hazardous material. the primary or subsidiary hazard class of the material shall be described by the technical name of I hope this satisfies your inquiry. Sincerely, Edward T. Mazzullo Director, Office of Hazardous Materials Standards 172101(c)(10) (i) 020125#

Page 2Gale, John Sent: From: rduzynski@mmm.com Subject: To: John.gale @erspa.dot.gov Wednesday, April 03, 2002 6:49 PM Gale Proper Shipping Name/Technical Name Selection for Mixtures $ 172. 101€1 John, I would like to confirm when a mixture or solution contains a hazardous material identified in the Hazardous Materials Table (HMT) by Classitication the mixture or solution (e.g., Div 2.1- Flammable Gas), it need not be echnical name (e.g., Chloroform) that does not contribute to hazards of 02-0125 name. I have provided six gas mixture scenarios with some potential proper included in the determination of the proper shipping name and/or technical choice shipping name and technical name choices displayed for each is shown in red) to illustrate my question and solicit your comments example (my on acceptability. appropriately describe" the discretion to decide what shipping name to use." Example #1 508 - Dimethyl Ether, 2.1, UN1033 50% - Non-hazardous material Mixture is a Flammable Gas (Div 2.1). Potential Proper Shipping Name Choices: Dimethyl Ether Mixture, 2.1, UN1033 Liquefied Gas, Flammable, N.O.S. (Contains Dimethyl Ether), 2.1, UN3161 Example #2 508 - Dimethyl Ether, 2.1, UN1033 498 18 - Chloroform, 6.1, UN1888, III - Non-hazardous material component (different hazard class) The mixture is a Flammable Gas (Div 2.1) and contains another hazardous that is specifically named in the HMT. Potential Proper Shipping Name Choices: Dimethyl Ether Mixture, 2.1, UN1033 Liquefied Gas, Flammable, N.O.S. (Contains Dimethyl. Ether), 2.1, UN3161 UN3161 Liquefied Gas, Flammable, N.O.S. (Chloroform and Dimethyl Ether), 2.1, technical name because Chloroform does not Note: I believe (Chloroform and Dimethyl Ether) would not be an mixture. contribute to hazard#

Page 3Example #3a Hazard, 958 - Silicon Tetrafluoride Compressed, 2.3, UN1859, Toxic-Inhalation 58 - Carbon Dioxide, 2.2, UN1013 Zone B, 8 another hazardous component 11xture 1s a loxic Gas (DIV L.3) with a Corrosive (8) subrisk and contain named in the HMT. (different hazard class) that is specificall. Potential Proper Shipping Name Choices: Silicon Tene #luoride Compressed Mixture, 2.3. UN1859, Taxie-Inhalation Compressed Gas, Toxic, N.O.S. (Contains Silicon Tetrafluoride), 2.3, UN1955, Toxic-Inhalation Hazard, Zone B, Compressed Gas, Toxic, N.O.S. (Carbon Dioxide and Silicon Tetrafluoride), 2.3, UN1955, Toxic-Inhalation Hazard, Zone B, 8 Note: I believe that Silicon Tetrafluoride Compressed Mixture (UN1859) and inclusion of Carbon Dioxide (Div 2.2- Non-Flammable Gas) in the appropriately describes this mixture; however, classification as UN1955 technical name would help identify the presence of the Carbon Dioxide which pressurization effect. could contribute to the overall hazard of the mixture due to its Example #3b 50% - Carbon Dioxide, 2.2, UN1013 50₴ - Dimethyl Ether, 2.1, UN1033 Mixture is a Flammable Gas (Div 2.1). Potential Proper Shipping Name Choices: Dimethyl Ether Mixture, 2.1, UN1033 Liquefied Gas, Flammable, N.O.S. (Contains Dimethyl Ether), 2.1, UN3161 2. 1, UN3161 Liquefied Gas, Flammable, N.O.S. (Carbon Dioxide and Dimethyl Ether), his mixture; however, classification as UN3161 and inclusion of Carbor Vote: I believe that Diethyl Ether Mixture (UN1033) appropriately describes ioxide (Div 2.2- Non-Flammable Gas) in the technical name helps identifies hazard of the mixture due to its pressurization effect. he presence of the Carbon Dioxide which could contribute to the overall Example #4 30% 50% - Carbon Dioxide, 2.2, UN1013 20% - Acetone, 3, UN1090, II - Non-hazardous material presence of the acetone (flammable liquid) being dispensed by a compressed The mixture is a flammable liquefied compressed gas (Div 2.1). due to the 2#

Page 4gas (Div 2.2) propellant. Potential Proper Shipping Name Choices: UN3161 Liquefied Gas, Flammable, N.O.S. (Acetone and Carbon Dioxide), 2.1, Liquefied Gas, Flammable, N.O.S. (Contains Acetone), 2.1, UN3161 Note: I believe (Acetone and Carbon Dioxide) would be the best technical name for the mixture because including Carbon Dioxide in the technical name "Gas" even though it is not a flammable component or a liquefied gas. helps explain the proper shipping name selection that includes the word Example #5 30% - Non-hazardous material 50% - Carbon Dioxide, 2.2, UN1013 108 - Acetone, 108 - Heptane, 3, UN1206, 3, UN1090, presence of the flammable liquids The mixture is a flammable liquefied compressed gas (Div 2.1) due to the a compressed gas (Div 2.2) propellant. (Acetone and Heptane) being dispensed by Potential Proper Shipping Name Choices: UN3161 Liquefied Gas, Flammable, N.O.S. (Acetone and Carbon Dioxide), 2.1, Liquefied Gas, Flammable, N.O.S. (Acetone and Heptane), 2.1, UN3161 the proper shipping name selection that includes the word "Gas" even though lame because includina it is not a flammable component or a liquefied gas. Example #6 40% 508 - Dimethyl Ether, 2.1, UN1033 10% - Acetone, 3, UN1090, II - Non-hazardous material hazardous component (different hazard The mixture is a liquefied compressed gas (Div 2.1) and contains another the HMT. come cet ne 18 flammazer woul cott tibute to cally named ir flammability of the gas mixture. Potential Proper Shipping Name Choices: UN3161 Liquefied Gas, Flammable, N.O.S. (Acetone and Dimethyl Ether), 2.1, Dimethyl Ether Mixture, 2.1, UN1033 Liquefied Gas, Flammable, N.O.S. (Contains Dimethyl Ether), 2.1, UN3161#

Page 5flammable without its presence due to the high percentage of Dimethyl Ether. me. If you have any questions or need additional information, please contact Thank you for your assistance in advance! 225-5N-07 Ray T. Duzynski Tel: 3М Transportation, Regulatory Compliance Fax: 651-733-6439 651-733-9042#