{"operation":"document","citation":"02-0162","title":"Johnson Matthey, Inc. — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2002-07-31","effective_on":null,"summary":"02-0162 response to Johnson Matthey, Inc. concerning 173.22.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-02-0162.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-02-0162.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-02-0162","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2002/020162.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\n400 Seventh St., S.W.\nWashington, D.C. 20590\nSpecial Programs\nResearch and\nAdministration\nJUL 31 2002\nMr. Bill Erickson\nRef. No. 02-0162\nOperations Manager\nJohnson Matthey,\nInc.\n1397 King Road\nWest Chester,\nPA 19380\nDear Mr. Erickson:\nThis is in response to your letter dated May 24, 2002, requesting\nclarification regarding the selection of a proper shipping name\nunder the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-\n180).\nSpecifically, you asked\nmaterial can be classified as \"Self-heating solid, inorganic,\nwhether your nickel catalyst\nn.o.s., 4.2, UN3190.\nFor a material not specifically identified by name in the\nHazardous Material Table (HMT), the HMR requires that the\nmaterial be described by the shipping name that \"most\nappropriately describe\" the material.\none shipping name could \"most appropriately describe a material.\"\nIn some cases, more than\nUnder § 173.22, it is the shipper's responsibility to properly\nclassify and describe a hazardous material. This office\ngenerally does not perform this function.\nassistance when we have the information available.\nHowever, we provide\ntesting performed on the material was inconclusive due to the\nIn your letter, you stated that the third party laboratory\ntemperature of the test\nsample climbing rapidly from ambient to\nover 300 °C within the first three minutes. You further stated\nthat the temperature continued to climb to over 400 oC within 10\nminutes, where it remained for approximately 30 minutes before\ndropping back down to ambient temperature two hours after the\nstart of the test.\nIn the HMR, § 173.124(b) defines a Division 4.2 (Spontaneously\nCombustible) as being one of the following:\n(1) A pyrophoric material. A pyrophoric material is a\nliquid or solid that, even in small quantities and\nwithout an external ignition source, can ignite with\nfive (5) minutes after coming in contact with air when\ntested according to UN Manual of Test and Criteria.\n\n<<<PAGE 2>>>\n\n(2)\nA self-heating material. A self-heating material is a\nmaterial that, when in contact with air and without an\nenergy supply, is liable to self-heat. A material of\nthis type which exhibits spontaneous ignition or if the\ntemperature of the sample exceeds 200 °C (392 oF)\nduring the 24-hour test period when tested in\naccordance with the UN Manual of Tests and Criteria, is\nclassed as\na Division 4.2 material.\nTherefore, based on the information you provided, in addition to\nthe fact that your material is heating up to a temperature of\nover 300 °C within the first three minutes upon contact with air,\nit is the opinion of this office that the proper shipping name\n\"Pyrophoric solid, inorganic, n.o.s., 4.2, UN3200\" most\nappropriately describes your nickel catalyst material.\nI trust this satisfies your inquiry. Please contact us if we can\nbe of further assistance.\nSincerely,\nNathe z. Michel\nHattie I. Mitchell :\nChief, Regulatory Review and Reinvention\nOffice of Hazardous Materials Standards\nun.\n\n<<<PAGE 3>>>\n\nBetts\nJohnson Matthey §73. 10t\nMay 24, 2002\nClassification\nEd Mazzullo\nDirector of Office of Hazardous Material Standards\n02-0162\nDHM-10 USDOT/RSPA\n400 7\" Street Southwest\nWashington, DC 20590.\nDear Mr. Mazzullo:\nMy company, Johnson Matthey Inc., is seeking an interpretation on third party laboratory testing\nwhich Stresau Laboratories Inc. performed on nickel catalyst material. The testing was\ninconclusive, however, Dr. Spence Watson of the DOT has recommended we classify this\nmaterial as Division 4.2, Packing Group II - Self-heating solid. Would you please let me know if\nyour Office concurs.\nThank you for your help in this matter. If you have any further questions, please contact me at\n610-232-1953.\nsincerely\nBill Erickson\nOperations Manager\nJohnson Matthey Inc.\nFuel Cells - GPT\n1397 King Road\nWest Chester, PA 19380\nEnclosure\nCATALYST AND CHEMICALS DIVISION - FUEL CELLS\nGAS PROCESSING TECHNOLOGY\n434 Devon Park Drive, Wayne, PA 19087-1889\n| TEL: (610) 971-3100, FAX: (610) 971-3116\n\n<<<PAGE 4>>>\n\n1HT-14-EUUE 10:10\nFRUM: SIRESHU LU ristssryry\nIU: 1610252195U\np:213\nSTRESAU LABORATORY INC.\n•\nN8265 Medley Road, Spooner, W1 54801-7819, Tel. 715-635-2777, Fax 715-635-7979 wwww.streaau.com\nMay 13, 2002\nMr. Allen Foster\nJohnson Matthoy\n1397 King Road\nWest Chester, PA 19380\nDear Mr. Foster:\nEnclosed please find Laboratory Report # 02069 for Division 4:1 Flammable Solid and 4.2 Self-\nHoat testing of your sample. Full details are in the enclosed report.\nn invoice to cover the cost of the laboratory examinations will be sent to your accountin\nepartment under separate cover. Your sampic remnants will be icturned to you shortl\nWe appreciate your business. If we may be of further assistance or if you have any questions,\nplease call me at (715) 635-2777.\nSincerely,\nthran E Baton\nThomas E. Basham\nHazardous Materials Manager\ntb (02069)\nIver Thirty ycars of Devclopment a Evaluation a Production of Ererretic Device\nClassification • Packaging a Testing of Hazardous Material\n\n<<<PAGE 5>>>\n\nMAY-14-2002 13:18\nFROM: STRESAU LAB 7156357979\nTO: 16102321930\nP: 3/5\nSTRESAU LABORATORY INC.\nNB265 Medley Road, Spooner, WI 54801-7819, Tel. 715-635-277. Fax 715-635-7979 www.stresal.com\nLABORATORY REPORT # 02069\n\"FLAMMABLE SOLID AND SELF-HEAT TESTING\"\nMay 13, 2002\nfor\nJohnson Matthey\n1397 King Road\nWest Chester, PA 19380\nAtin: Mr. Allen Foster\nPrepared by: thomE Botan\nThomas E. Basham\nHazardous Materials Manager\nReviewed by:\nlichael J. Pesk\n- MinaPart\nChief Operating Officer\nver Thirty years of Development a Evaluation • Production of Enorgotic Devics\nlassification • Packzging o Testing of Hazardous Materia\n\n<<<PAGE 6>>>\n\nMHY-14-2402 15:18\nFROM: STRESAU LAB 7156357979\nTO: 16102321930\nP: 4/5\nSTRESAU LABORATORY, INC.\nMay 13, 2002\nLABORATORY REPORTS NO. 02069\nPage 1 of 2\nPrepared for: Johnson Matthey\n1397 King Road\nWost Chester, PA 19380\nSubjcct: Preliminary Screen and Self- Heat Test\n1.0 OJECT\nYour sample identified as Ni-3288 E 1/16\" 3F Nickel Catalyst was subjected to a Preliminary\nScreen/Burn Rate and Self-Heating Test in accordance with the Code of Podoral Regulations,\nTitle 49, (also United Nations Test Mcthod N.1 and Test Method N.4) as reguested by Rob\nSmith, Cargopak Corp., P.O. # 02-2066 dated March 18, 2002.\n2.0 PHYSICAL APPEARANCE\nThe sample was a black extrusions contained in a metal cylinder, 10\"L × 1\"od, with\nSwage-Lok pipe fittings and caps on both ends. The sample was prepared for testing by\nopening one end and pouring the contents into the proper test fixtures.\nThe sample arrived at Stresau at ambient terperaturo, and was tested in the form received.\n3.0 TEST CONDUCTED\n3.1 Class 4.1 Preliminary Screen Test, UN method N.1\nProcedure\nA portion of the sample is filled into a metal mold 250mm long by 20mm wide by 10 mm high,\nand inverted onto a cool, impervious base plate. The sample is ignited by application of a gas\nburner at one end, and the titte needed to propagate 100 mm is recorded.\n4.0\nSUMMARY\nUpot pouring the sample into the metal mould, it itamediately began to heat in contact with\nair and without an ignition source. A color change from black to gray further indicated that\na reaction was taking place. A gas flame was applied to on end, but no additional changes\noccutted.\n\n<<<PAGE 7>>>\n\nInI\n1 T\nLOU dO IAUIVINLUMU A FUNDIS\nIN• LULULULAINN\nSTRESAU LABORATORY, INC.\nMay 13, 2002\nLABORATORY REPORTS NO. 02069\nPage 2 of2\n5.1 Class 4.2 Self Heating Test, UN method N.4\nProcedure\nA portion of the sample (as received) was prepared for testing by filling a 1.0cm' fine mesh stainless\nsteel wire basket. The basket was tested by placing it into an oven set at 140°C (284°F) with a\nthermocouple probe and a wiro mesh basket cover. The temperature of the sample and oven are\nrecorded throughout the test.\n6.0 SUMMARY\nApproximately 100 grams of sample was poured into a 10cma? fine mesh stainless sicel wire\nbasket at ambient temperature. The sample immediately began to generate heat. A thermocoup)\nvas placed in the sample. The sample temperature climbed rapidly from ambient to over 300°C\nwithin the first threc minutes. The temperature continued to climb to ovcr 400°C within 10 minutes\nafter insertion, where it remained for approximately 30 minutes before dropping back down to\nambient temperature two hours after the start of the tost.\n7.0 CONCLUSIONS\nTest results from the Preliminary Screen and Self-Heat Tests are inconclusive due to the materials\nability to generate significant heat before complete application of UN/DOT methodology such as\nflame contact in the Preliminary Screen and 140°C atmosphere in the Self-Heat Test.\n8.0 DATA STORAGE\nThe field data for this report is contained in Data Book #SLF 2002-1, and will be filed with\nStrosau Laboratory Document Control. No photographic or video documentation was made.","truncated":false,"body_characters":8795}