Baff Incorporated — Hazardous Materials Safety Interpretation

Page 1400 Seventh St., S.W. Washington, D.C. 20590 dministration DEC 2 3 2002 Mr. John Rhodes .O. Box 1879 Barr Incorporates Ref No. 02-0281 Memphis, TN 38113 Dear Mr. Rhodes: This is in response to your October 16, 2002 letter asking if the Research and Special Programs Administration (RSPA) would consider the separation of the corrosive class into two divisions; i.e,. materials that are corrosive only to metals and materials that are corrosive only to skin. (U.N. Committee) is considering the separation of Class 8 (Corrosive) materials into two or more Currently, neither this Office or the United Nations Committee on the Transport of Dangerous Goods divisions. In fact, the U.N. Committee has considered this issue in the past and decided that separation is not necessary. It you wish to provide this information to your customers, you are permitted to add additional information, such as "skin corrosive only" following the required shipping descriptions on shipping papers and package markings.. I hope this information is helpful. If we can be of further assistance, do not hesitate to contact us. Sincerely, Delmer F. Billings Chief, Standards Development Office of Hazardous Materials Standards 173.136 020281#

Page 2Foster barr $173.136 Definitions October 16, 2002 02-8281 U.S. Department of Transportation Research and Special Programs Administration 400 7* Street, S.W. Office of Hazardous Materials Safety Washington, DC 20590 Attn: Hattie L. Mitchell To Whom It May Concern: My question is, would RSPA consider the separation of the corrosive class into two parts; those materials that are corrosive to inetals and those that are corrosive to the skin only? My company packages paint removers for use with various types of paint and, on various types of materials. Some of these removers are corrosive, others are flammable to some degree. None of these are corrosive to metal, only to you r skin. The reason I ask is, we have had, a good number of our customers, that export our removers, ask if the ones that are corrosive; are they corrosive to the skin or metal. I look forward to your comments: Sincerely The has John Rhodes 2105 Channel Barr Incorporated Memphis, TN 38113 Ph 800.782.9926 Ex 800.521.9508#