Honeywell — Hazardous Materials Safety Interpretation

Page 1: U.S. Department of Transportation Washington, D.C. 20590 400 Seventh St., S.W. Special Programs Research and Administration JUL 10 2003 Ms. Barbara Konrad Ref. No. 02-0318 Manager, Transportation Safety Honeywell P.O. Box 1057 Morristown, NJ 07962-1052 Dear Ms. Konrad: This is in response to your letter, e-mail, and telephone conversation with Sandra Webb of my staff regarding the applicability of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) to hermetically sealed sensing elements. Specifically, you request confirmation that the sensing elements once incorporated into their final product, may be transported without being subject to the HMR. I apologize for the delay in responding and hope it has not caused any inconvenience. According to your letter, each sensing elements is a copper metal capsule that contains approximately 11 - 20 ml of certain flammable liquids and other gases listed below: Toluene, 3, UN 1294, PG II Ethyl ether, 3, UN 1155, PG I Flammable liquid, n.o.s. (Isopropyl alcohol), 3, UN 1993, PG III Isobutane, 2.1, UN 1969 Ethyl chloride, 2.1. UN 1037 You further state that most of the sensing elements in the group contain toluene. However, all of the materials listed above function as a temperature sensing fluid inside the element. You question the following scenario: The sensor elements are constructed (point A), "aged" and shipped to your assembly plant in accordance with the small quantity exception in § 173.4. At the assembly plant (point B), the sensor elements are incorporated into the final product. Each final product is placed in an intermediate packaging with cushioning and then placed into a strong, corrugated outer packaging and shipped to your distribution facility (point C). At the distribution facility, the outer packaging is broken down and the final products are placed with other non-hazardous materials and once again placed in a strong, corrugated outer packaging and shipped to customers (point D). In your opinion, because of the small quantities of hazardous materials, the sensor design, construction, and protective packaging, the sensors in the final products#

Page 2shipped from point B to point C and point C to point D do not pose a significant hazard to health during transportation and, as a result, the sensors should not be subject to the HMR. Based on the information you submitted and the information available to us, the final products containing the sensing elements are subject to the HMR for the following reasons: Small quantities of Class 3, Division 4.1, Division 4.2 (PG II and III), Division 4.3 (PG II and III), Division 5.1, Division 5.2, Division 6.1, Class 7, Class 8, and Class 9 materials that also meet the definition of one or more of these hazard classes, are eligible for the small quantity exceptions in § 173.4. However, as noted, the Isobutane, 2.1, UN 1969 and Ethyl chloride, 2.1, UN 1037 sensors are Division 2.1 flammable gases and are not eligible to be transported under the small quantity exceptions in §173.4. These sensors must be transported as follows: a. With regard to the Isobutane sensor, it must be packaged in accordance with §$173.306 or 173.304 as designated in column &A or 8B of the Hazardous Materials Table. However, you may take advantage of the limited quantities exception for compressed gases in § 173.306 provided all of the provisions are met. In addition, Isobutane packaged as a limited quantity, in accordance with § 173.306, that meets the definition of a consumer commodity may be reclassed as an ORM-D material and transported as a consumer commodity. b. With regard to the Ethyl Chloride sensor, there are no packaging exceptions authorized in Column 8A of the HMT. Therefore, it must be packaged in accordance with § 173.322 as designated in Column 8B of the HMT. 2. With regard to the Toluene, Ethyl ether and Flammable liquid, n.o.s. (Isopropyl alcohol) sensors, it is our opinion that they may be transported under the small quantity exceptions provided the quantity of the Class 3 material in the inner packaging does not exceed thirty (30) mi and all other provisions of § 173.4 are met. However, you may choose to take advantage of the limited quantities exceptions for flammable liquids in § 173.150 provided all of those provisions are met. In addition, if a flammable liquid is packaged as a limited quantity, in accordance with § 173.150, and meets the definition of a consumer commodity, it may be reclassed as an ORM-D material and transported as a consumer commodity. I trust this satisfies your request. If we can be of further assistance, please do not hesitate to contact us. Sincerely, Shain Drof Susan Gorsky Senior Regulation Specialist Office of Hazardous Materials Standards#

Page 3NOU-21-2002 10:16 P.01/03 Honeywell Honeywell P.O. Box 1057 Webb Morristown, NJ 07962-1057 872.101.5 VIA FAX (202) 366-3012 Applicability pages =3 09-0318 US Department of Transportation 400 of treet sious Materials Standards Washington, DC 20590 Attention: ED MAZZULLO, DHM-10 Re: Request For Clarification On Applicability Of HMR To Heretically-Sealed Copper Sensing Elements Dear Mr. Mazzullo: Hazarius Materials Regulations MR, 49C..R. Parts 7 80 i a giry t hermetically-sealed copper sensing elements that contain small quantities (< 20 ml) of toluene or other fill materials. Because of the design, construction, and packaging of this group of sensing elements, Honeywell believes that the hazardous materials present in the elements do not pose a significant hazard to health during transportation and, as a result, that the group should not be subject to the HMR. The purpose of this letter is to describe the sensing elements and to seek clarification as to whether the group of elements is excepted from the HMR. Description Of Sensing Elements. Each sensing element is a copper metal capsule, ranging from 2 to 4 inches in length and from 0.375 to 0.50 inches in width. A small amount (< 20 ml) of certain flammable liquids and/or gases (listed below) is introduced into each capsule. After each sensing element is hermetically sealed, the element is subjected to an aging process in which it is heated in an oven for 40 hours at temperatures ranging from 115 to 190 degrees Fahrenheit. During this process, no hazardous materials are released from the element, nor is there deformation or degradation of the element. The sensing elements cannot be broken apart absent the deliberate use of a tool. The vast majority of elements in the group contain toluene (3, UN1294, PG II), which functions as a temperature sensing fluid inside the element. The following fill materials, with identical functions, also are contained in a minority of the sensing elements; Ethyl ether, 3, UN1155, PG| Flammable liquid, nos (isopropyl alcohol), 3, UN1993, PG III • Isobutane, 2.1, UN1969 Ethyl chloride, 2.1, UN1037 • Honeywell Temperature Sensor Interpretation Request Page 1#

Page 4NOU-21-2002 10:16 P.02/03 - Packaging And Transport. The elements are offered for transportation by motor vehicle and cargo aircraft. As protection during transport, the sensing elements are first shipped in sturdy plastic bins. Once the elements are assembled into final products, they are shipped in strong outer packages. Both the sensing elements and the plastic bins in which they are transported have passed drop tests from 1.8 meters. Additionally, all of the elements subjected to compressive load tests passed without incident. The hermetically-sealed sensing elements have passed these rigorous tests and cannot be opened absent deliberate use of a tool. Therefore, the risk is negligible that hazardous materials will be released from the elements under conditions normally incident to transportation. Conclusion And Summary. The design, construction, and shipment of Honeywell's class of sensing elements remove virtually all risk of leakage during transport. Honeywell therefore believes that the class of elements can be transported safely without being subject to the HMR. For your reference, we have attached a letter of clarification dated November 6, 2000, in which you determined that certain sealed glass tubes containing trace gases were not subject to the HMR. We believe that the reasoning in that letter applies equally to Honeywell's group of sensing elements. Honeywell's sensors, in fact, are less hazardous to health during transportation because they are made of copper, not glass, and thus are effectively non-breakable. We respectfully request that you confirm that Honeywell's group of elements is excepted from the HMR. We appreciate your attention to this matter. Should you have any questions or require additional information regarding Honeywell's sensing elements, please do not hesitate to call me at (973) 455-4009 or email me at barbara.konrad@honeywell.com. Bihu Knual Barbara Konrad Attachment Honeywell Temperature Sensor Interpretation Request Pago 2#

Page 5of Transportation U.S. Department Washington, D.C. 20590 400 Seventh St., S.W. Special Programs Research and Administration JUL 1 0 2003 Ms. Barbara Konrad Manager, Transportation Safety Ref. No. 02-0318 Honeywell P.O. Box 1057 Morristown, NJ 07962-1052 • Dear Ms. Konrad: This is in response to your letter, e-mail, and telephone conversation with Sandra Webb of my staff regarding the applicability of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) to hermetically sealed sensing elements. Specifically, you request confirmation that the sensing elements once incorporated into their final product, may be transported without being subject to the HMR. I apologize for the delay in responding and hope it has not caused any inconvenience. According to your letter, each sensing elements is a copper metal capsule that contains approximately 11 - 20 ml of certain flammable liquids and other gases listed below: Toluene, 3, UN 1294, PG II ••. Ethyl ether, 3, UN 1155, PG I Flammable liquid, n.o.s. (Isopropyl alcohol), 3, UN 1993, PG III Isobutane, 2.1, UN 1969 • Ethyl chloride, 2.1. UN 1037 You further state that most of the sensing elements in the group contain toluene. However, all of the materials listed above function as a temperature sensing fluid inside the element. You question the following scenario: The sensor elements are constructed (point A), "aged" and shipped to your assembly plant in accordance with the small quantity exception in § 173.4. At the assembly plant (point B), the sensor elements are incorporated into the final product. Each final product is placed in an intermediate packaging with cushioning and then placed into a strong, corrugated outer packaging and shipped to your distribution facility (point C). At the distribution facility, the outer packaging is broken down and the final products are placed with other non-hazardous materials and once again placed in a strong, corrugated outer packaging and shipped to customers (point D). In your opinion, because of the small quantities of hazardous materials, the sensor design, construction, and protective packaging, the sensors in the final products#

Page 6shipped from point B to point C and point C to point D do not pose a significant hazard to health during transportation and, as a result, the sensors should not be subject to the HMR. Based on the information you submitted and the information available to us, the final products containing the sensing elements are subject to the HMR for the following reasons: 1. Small quantities of Class 3, Division 4.1, Division 4.2 (PG II and III, Division 4.3 (PG II and III, Division 5.1, Division 5.2, Division 6.1, Class 7, Class 8, and Class 9 materials that also meet the definition of one or more of these hazard classes, are eligible for the small quantity exceptions in § 173.4. However, as noted, the Isobutane, 2.1, UN 1969 and Ethyl chloride, 2.1, UN 1037 sensors are Division 2.1 flammable gases and are not eligible to be transported under the small quantity exceptions in §173.4. These sensors must be transported as follows: With regard to the Isobutane sensor, it must be packaged in accordance with §$173.306 or 173.304 as designated in column 8A or 8B of the Hazardous Materials Table. However, you may take advantage of the limited quantities exception for compressed gases in § 173.306 provided all of the provisions are met. In addition, Isobutane packaged as a limited quantity, in accordance with § 173.306, that meets the definition of a consumer commodity may be reclassed as an ORM-D material and transported as a consumer commodity. b. With regard to the Ethyl Chloride sensor, there are no packaging exceptions authorized in Column &A of the HMT. Therefore, it must be packaged in accordance with § 173.322 as designated in Column 8B of the HMT. 2. With regard to the Toluene, Ethyl ether and Flammable liquid, n.o.s. (Isopropyl alcohol) sensors, it is our opinion that they may be transported under the small quantity exceptions provided the quantity of the Class 3 material in the inner packaging does not exceed thirty (30) ml and all other provisions of § 173.4 are met. However, you may choose to take advantage of the limited quantities exceptions for flammable liquids in § 173.150 provided all of those provisions are met. In addition, if a flammable liquid is packaged as a limited quantity, in accordance with § 173.150, and meets the definition of a consumer commodity, it may be reclassed as an ORM-D material and transported as a consumer commodity. I trust this satisfies your request. If we can be of further assistance, please do not hesitate to contact us. Sincerely, Xusan Dook Susan Gorsky Senior Regulation Specialist Office of Hazardous Materials Standards#

Page 7Webb, Sandra From: Sent: Konrad, Barbara (MTO) [barbara.konrad@honeywell.com] To: Friday, February 21, 2003 1:40 PM Subject: Cc: 'sandra.webb@rspa.dot.gov' SENSOR INTERP Schmolke, Colleen (MN10) HON ethyl chloride MPEG sensor insi... HON ethyl chloride LPEG sensor finl... SENSOR SMALL QTY PKG.JPG Sandra, I understand your position on the sensors leaving our plexiglass bins being subject to the HMR (small quantity exception 173.4) but would like an opportunity to explain in final products. greater detail why the HMR should NOT APPLY to the sensors once they are incorporated intr SENSOR TRANSPORTATION FLOW: * rigid fiberglass bins for Sensors elements are constructed (point A), "aged" (see below) then placed into continue to ship these shipment to the assembly plant. You already have photos of the sensor elements. We will sensors, in the bins, in accordance with the small quantity exception in 49 CFR 173.4. * product. At the assembly plant (point B) the sensor elements are incorporated into the final You already have a photo of the final product. These final products are wrapped in bubble wrap, placed into a Honeywell product box a distribution facility (point (cardboard) and then placed into an overpack (fibreboard box). These are then shipped to C) sensors from point B to point C A copy of this packaging is provided below. We do not believe the shipment of the should be covered under the HMR. packaged final products are placed At the distribution facility, the boxes are broken down and the individually (with other non-hazardous materials) an overpack (fibreboard box) for shipment to final believe the shipment of the sensors from point C to point D should be covered under the customers (point D). HMR. The facts supporting the non-applicability of the HMR are these: Sensors contain approximately 11 - 20 ml of hazardous material, a very small amount for any hazardous material Sensors are made of metal and are hermetically sealed. It is virtually impossible to escape from the sensors under conditions normally incident to transportation. them in an oven at either 115F Prior to shipment they are subjected to rigorous testing. This includes "aging" or 190F for a minimum of 40 hours. During this aging process, the sensors do not release any hazardous material and are not deformed in any way. This would indicate that even in an upset condition during transportation, hazardous material would not be released. wrap cushioning surrounding The final products (with the sensor inside) are packaged one to a box with bubble the product. This is then placed inside a Honeywell product box. shipped to our distribution These product boxes are packed 24 to a "case" (strong, solid fibreboard box). when 1#

Page 8facility. items ordered by oux From the distribution facility, each individual product box is packed (with other customers) into a new overpack (strong, solid fibreboard box) and shipped to the customer. Here are photos of the : bubble wrapped sensor <<Bubble wrapped sensor. JPG>> the product box (containing the bubble wrapped sensor) <<HON sensor product box. JPG>> the overpack into which the product boxes are placed for shipment <SENSOR OVERPACK. JPG>> because of the small quantities, the I hope this provides you with the additional information you need to determine that subject to the HMR. sensor designs and the protective packaging, the sensors in the final products are not So any hay ne can to desire ate give so ana to no can discuss. I appreciate your Barb Manager, Transportation Safety Barbara Konrad 973-455-4009 (phone) 617-344-3093 (fax to PC) 973-722-2574 (cellular) 973-455-3491 (alternate fax) 2#

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Page 13= Honeywell Honeywell P.O. Box 1057 Morristown, NJ 07962-1057 Via e-mail: sandra.webb@rspa.dot.gov December 19, 2002 Associate Administrator for Hazardous Materials Safety Research and Special Programs Administration US Department of Transportation 400 7th Street, SW Washington, DC 20590-0001 Attention: SANDRA WEBB - INTERPRETATIONS Re: Photos of Toluene Sensors and Shipping Bins As a follow up to Honeywell's request for a formal interpretation on the applicability of the Hazardous Máterials Regulations (HMR) to hermetically sealed sensing elements, we are providing photos of the sensing elements, the shipping bins and the final product which contains the sensing element. THIS IS A PHOTO OF THE SENSING ELEMENT AT MANUFACTURING FACILITY The toluene is contained in the 3" long capsule in the left of the photo. These sensors are loaded into plastic bins (with covers) for shipment to final assembly facility. There the parts are incorporated into the final temperature sensing / control device. These are the plastic bins into which are placed the temperature sensors. The covers at then snapped into place before shipping to the final product assembly location.#

Page 14• Honeywell International Request for Interpretation - Toluene Sensor Follow-up Page 2 Each tempertaure sensor is assembled into the final products, individually boxed within final product packaging, and then shipped to a distribution center for shipment to customers. The distribution center overpacks these devices into fibreboard boxes, usually with other non-regulated items. HOHEKNEEL As a separate attachment to this e-mail, I am including the pdf engineering specification for the toluene sensors, which is identified as "ES05142". I hope that this additional information is helpful. We look forward to hearing of your decision that these sensors are not subject to the HMR because they (1) contain such small amounts of hazardous material; (2) are constructed of solid, leak-proof metal; and (3) are over packed for shipment in either leak-proof plastic bins or in fibreboard boxes. Should you require any additional information, please don't hesitate to call me at 973- 455-4009 or via e-mail at barbara.konrad@honeywell.com. Happy Holidays! Barbara Konrad Manager, Transportation Safety#

Page 15• Honeywell International Request for Interpretation - Toluene Sensor Follow-up Page 2 Cc: Colleen Schmolke#

Page 16.. r Honeywell International Request for Interpretation - Toluene Sensor Follow-up Page 2#

Page 17- • HONEYWELL No. E$ 15042 ENGINEERING SPECIFICATION SOLD FILLED DIAPHRAGM TYPE SENSING ELEMENTS Page 1 of 4 Current Issure Date: 11/30/93 Released to Production: DISTRIBUTION Original Issue Date: 11/30/93 Supersedes: 04/23/85 MEXICO ARLHIS TOKYO X Development No. TORONTO APPROVAL DATE DESIGN MANAGER (Section I): PROCESS MANAGER (Section II): D. M. Saunderson D. M. Putnam QUALITY MANAGER: REVIEWED BY: REVISION HISTORY DATE PAGES PAGES PAGES ECO REVISED 11/30/93 Revised & Retyped Supersedes DATE ECO REVISED DATE ECO REVISED 92-1189 04/23/85 • No. ES 15042 Page 1 0f4 ED'd 0500067-40-2#

Page 18• ... • • HONEYWELL ENGINEERING SPECIFICATION No. ES 15042 SOLI FILLED DIAPHRAGM TYPE SENSING ELEMENTS Page 2 of 4 SECTION I - GENERAL DESIGN SPECFICATIONS Current Issue Date 11/30/93 A. General Description of Device completely filled with a termal sensing fluid which expands with an inorease in temperature. This volume increase in the tluid causes the diapbragm of the element to have its "Travel." The specific characteristics of the elements are set forth in tabulation form on the element prints. B. Definition of Terms • The ranges listed on the element prints are not necessarily the limits of the clements but could be • The nominal diaphragm travel per degree F of change in temperatute at the capsule is a reference the limits of the requirements of the device for which an element is intended. value and is not to be checked. • The active temperatute is the temperature at which the diaphragm will not be more than 030" below the standard reference position taking into consideration the diaphragm position tolerance stop by the bottoming of the diaphragm housing. under filling conditions. At this temperature, the diaphragma must still be free to travel and not • The maximum temperature is the highest temperature to which the clement should be subjected. and/or a shortening in the life of the diaphragt if cycled to these temperatures. Higher temperatures could cause a calibration shift in the device to which the olement is applied • The maximum deflection at the maximum temperature is the travel above the standard reference position at this temperature. It is calculated from the clement travel and the diaphragm position the maximum deflectión is also for information purposes and not to be checked. and tolerance under fill conditions. The diaphragm travel per degree is a reference value and so • Deflection is the perpendicular distance, the center flat portion is moved from this plane. observed without diaphragm load. Deflection toward the housing is considered to be negative and away from the housing positive. PAAN: BARBARA KONRAD FRoM: COLEN SCHMAKE 0.0031 gallons Toluene/capsule =1173mL Toluene 882062 TØ'd 20006-20-2#

Page 19MAR-07-1900 01:31 P.09 1P1. YAS, GOKAXIO MULS 7 RE PRAY S4NDODS K m D8tL1 f1211ng, FOLION D$ 5362 fo5 REVISION" TKIS- 123914 Opnie Stoche ID. tolun 5:/34 B-1 7-1/47 - 30 399₴ Avastid Capsúle - (130) sungaid Coprele -(125563 • = Top Connectirg Capillary" Capillary rasopoly datali. /honge Scry fut/te/swar(197002-Kes:) Hư I - Top Gonaşteing Capillary & Welded Pad. DN: 137986 NESB (123914. Rgf.) ... • stalacton of the codes N t02. 43. 16" 150 2. DALBUE ANSEOLI copper. Doppe серрат copper CATILINRY Sse CAn tate e 11e. and f411 tube) Tare d 11a ( 2l fuge eo outa orle: SUPERSEDE5 .O-KD. SUPERSEDEO BY 0° t0110% 30* to 190°g 30" to 220 3 40" tD 100*T* to 70°g • 60° to 200 T 110° ка 290°г 10 NG 246°g Copper Correc (heterdaa Tõr ardstlos DE a torsth. Irtbe: W111 Ledicta & connlete 21lled andesały appltcable the adeltfen of lettero fiom n oode WiL be ueed de itticate sat cenatscucia cRe. 120 to 950%. A to. 100 F o2 ly) Thala sualier uitb ebraz, legtara wLI1 Indicate e complate ansensly aszorE даке 11-22-55° RATE 2-25-69 DRENAHE SON AEd ON ARDBAR1 # INACTIVE - 248" Coypst - 124" Copper " Ii coppet With lean, chars threz letterz, thin rooker mosne nathiog. •HONEYWELL INC. 21-2/4"Coрдer 33-1/4 Copper - 39-1/4 Сорявс 4-1/44 соррос [EFAND 2" HIN ESASED .CAPSULE-(125583 - 35-3/8* соурок (яна оліт, 108032XXXX 10 4436 .D2 $362 a o-E0 A0 3-31-878083-160 LAS 2-17-5424-309 14005 SEL. Mad FILL TINE Toluene TOTAL P.09#

Page 20...€ - : HONEYWELL ENGINEERING SPECIFICATION No. ES 15042 SOLID FILLED DIAPHRAGM TYPE SENSING ELEMENTS Page 4 of 4 SECTION II - FACTORY SPECIFICATIONS Current Issue Date 11/30/93 A. Process Requirements (cont.) 3. Instructions for Filling (cont.) cotion in Ta craving a min a sea do care a into me pump times: Minimura time - 8.0 × 10-6 VL where: time is in minutes volume la cubic inches of the inside volume of the capillary plus the volume of the system to be evacuated through the capillary he inside diameter of the capillary in inche he length of the capillary in inche Note: Use nominal piece part dimensions for this calculation. d. Seal fill tube per element print. 4. Aging of Filled Elements %. Regical element that do not me to diplingm defection at standard emperature • • : No. ES 15042 Page 4 of 4 BE:10 06-L0-#

Page 21DEC-19-2002 10:51 P.01/02 Honeywell'" P.O. Box iOST. . Honeywell- Momstown, NS - 07962-1057 202-366-3012 Via e-mail: sandra.webb@rspa.dot.gov Fax = 2 pages. December 19, 2002 Associate Administrator for Hazardous Materials Safety .. Research and Special Programs Administration US: Department of Transportation 400.74 • Street, SW Washington, DC 20590-0001 Attention: SANDRA WEBB - INTERPRETATIONS) Re: Photos of Toluene Sensors and Shipping Bins ... Aș.a follow up to Honeywell's request for a formal interpretation on the applicability of the Hazardous Materials Regulations (HMR) to hermetically sealed sensing elemerits, which contains the sensing element. we are providing photos of the sensing elements, the shipping bins and the final product THIS IS A PHOTO OF THE SENSING ELEMENT AT MANUFACTURING FACILIȚY. The toluene is contained in the 3" long capsule in the left of the photo. These sensors are loaded into plastic bins (with covers) for shipment to final assembly facility. There the parts are incorporated into the final temperature sensing / control device. These are the plastic bins intó which are placed the temperature sensors. The covers at then snapped into place before shipping to the final product assembly location.#

Page 22DEC-19-2002 10:51 P:02/82 Honeywell International Request for Interpretation - Toluene Sensor Follow-up Page.2: Each tempertaure sensor is assembled into the final products, individually boxed within final product packaging, and then shipped to a distribution; center.- for shipment to customers. The distribution center overpacks these devices into items. fibreboard boxes, usually with other non-regulated.." As a separate attachment to this e-mail, I am including the pdf engineering specification for the toluene sensors, which is identified as "ES05142". I hope that this additional information is helpful. We look forward to hearing of your decision that these sensors are not subject to the HMR because they (1) contain such small amounts of hazardous material; (2) are constructed of solid, leak-proof metal; and (3) are over packed for shipment in either leak-proof plastic bins or in fibreboard boxes. Should you require any additional information, please don't hesitate to call me at 973- 455-4009 or via e-mail at barbara.konrad@honeywell.com. Happy Holidays! Barbara Konrad Manager, Transportation Safety .. ; -.Colleen Schmolke. :..: ' : . - TOTAL P.02 **#