Fisher Chemicals — Hazardous Materials Safety Interpretation

Page 1U.S. Department 400 Seventh St., S.W of Transportation Research and JUN 13 2003 Nashington, D.C. 20590 Administration Special Programs Ms. Jeanette DeGennaro Ref. No. 03-0096 Regulatory Specialist Fisher Chemicals 1 Reagent Lane Fair Lawn, NJ 07410 Dear Ms. DeGennaro: This is in response to your March 25, 2003 letter, requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to labeling. You state Sodium Peroxide, UN 1504 is specifically listed in the Hazardous Material Table (HMT) as a Class 5.1 Oxidizer. You state your company believes Sodium Peroxide is also a corrosive material. You question if the package for this material can be labeled with a Class 5.1 and Class 8 label. Your letter does not provide information (e.g. Material Safety Data Sheets) or indicate the method(s) used by your company in concluding this material is a corrosive material. As defined in § 173.136, a corrosive material means a liquid or solid that causes full thickness destruction of human skin at the site of contact within a specified period of time. A liquid that has a severe corrosion rate on steel or aluminum based on the criteria in § 173.137(c)(2) is also a corrosive material. If human experience or other data indicate that the hazard of a material is greater or less than indicated by the results of the tests specified in this section, the Research and Special Programs Administration (RSPA) may revise its classification or make the determination that the material is not subject to the requirements of part 173. As provided in § 172.402, each package containing a hazardous material shall be labeled with primary and subsidiary hazard labels as specified in column 6 of the HMT. Sodium Peroxide is a Class 5.1 material and is not assigned a subsidiary hazard class; therefore, additional labeling is not required. However, if you have data showing corrosivity of this material tested in accordance with § 173.137, you may affix a subsidiary hazard label in accordance with § 172.401, which states that no person may offer for transportation and no carrier may transport a package bearing a label unless the label represents a hazard of the material in the package. Please provide us with such data in accordance with § 172.101(d)(2). 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 172.402 030096#

Page 2Foster 8172.101 Fisher Chemicals §172.402 (a)(z) A Fisher Scientific Company Applicability 03-0096 March 25, 2003 Director, Office of Hazardous Materials Standards Mr. Edward T. Mazzullo 400 7th Street S.W. U.S. DOT/RSPA (DHM-10) Washington, D.C. 20590-0001 Re: Clarification of the use of 49CFR 172.402(a)(2) Requestor: Fisher Scientific Chemical Division 1 Reagent Lane Fair Lawn, NJ. 07410 201-703-3136 Attn: Jeanette DeGennaro degennaro@fisherchem.com Mr. Mazzullo: Sodium Peroxide is specifically listed in the hazardous materials table, 172.101, as Sodium Peroxide, 5.1, UN1504, I. Fisher believes that Sodium Peroxide is also a DOT corrosive. Is it acceptable, under marked with the proper shipping name, UN ID number and bearing both a 5.1 Oxidizer label and a Class 8 172.402(a)(2), to prepare and ship this material as Sodium Peroxide, 5.1, UN1504, I-the outer carton label? Any clarification you can provide is greatly appreciated. Best Regards, Fisher Scientific Chemical Division planetle Decernar Regulatory Specialist Jeanette DeGennarc#