Science Kit & Boreal Laboratories — Hazardous Materials Safety Interpretation

Page 1- of Transportation U.S. Department JUL 17 2003 400 Seventh St., S.W. Research and Washington, D.C. 20590 Administration Special Programs Mr. Rupert Zellner Ref. No. 03-0119 Warehouse Manager Science Kit & Boreal Laboratories 777 East Park Drive Tonawanda, NY 14150-6784 Dear Mr. Zellner: This is in response to your May 8, 2003 letter, requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the shipment of ORM-D materials. Specifically, you ask if the materials listed in your letter may be shipped as ORM-D materials. Your company is a supplier of education equipment, supplies, and chemicals to schools throughout the United retail market. States. You state the chemicals listed in your letter are packaged in a way that is suitable for sale in the Section 173.22 requires a shipper to properly class and describe the hazardous material in accordance with parts 172 and 173 of the HMR. This Office does not perform that function. As defined in § 171.8, a consumer commodity means a material that is packaged and distributed in a form intended or suitable for sale through retail sales agencies or instrumentalities for consumption by individuals for purposes of personal care or household use. This term also includes drugs and medicines. As provided in § 173.144, an ORM-D material means a material such as a consumer commodity, which, although otherwise subject to the regulations of this subchapter, presents a limited hazard during transportation due to its form, quantity and packaging. It must be a material for which exceptions are provided in Column 8A of the Hazardous Material Table (HMT) found under § 172.101. If the materials you intend to ship meet these criteria, then they may be renamed "Consumer commodity" and reclassed as "ORM-D." Materials properly renamed consumer commodity and reclassed ORM-D are excepted from labeling, placarding, specification packaging and, except when transported by air, are excepted from shipping paper requirements. However, packages containing consumer commodities must be marked in accordance with $ 172.316. I hope this information is helpful. If we can be of further assistance, do not hesitate to contact us. Sincerely, won bash susan Gorsk Senior Transportation Regulations Specialist Office of Hazardous Materials Standards 172.10 030119#

Page 2Science Kif Foster &Boreal Laboratories $172.101 May 8, 2003 ORM 03-0119 Office of Hazardous Material Standards Department of Transportation/RSPA/OHMS 400 7" Street SW Washington, DC 20591 To Whom It May Concern: We are contacting your office concerning the shipping of Limited Quantity chemicals as ORM-D material. Science Kit is a supplier of educational equipment, supplies, and chemicals to schools throughout the United States. The chemicals we distribute to schools are packaged in such a way that they could be sold in the retail market. Our understanding is that if a chemical presents a limited hazard during transportation as packaged for the retail market; it can be shipped as an ORM-D material. due to the quantity, packaging, and is an exception provided in the 172.101 Table, as well to have a ruling if these chemicals can be shipped as ORM-D material: Below is a sample list of chemicals we supply to the education market that we would like 125ml & 500ml Acetone 125ml & 500ml Ethanol Class 3 UN1090 PGII LTD Qty 125gm & 500gm Lead Compound •Class 3 UN1170 PGII LTD Qty (Lead Chloride) NOS Class 6.1 UN2291 PGIII LTD Qty 250ml & 500ml Hydrochloric Acid 125gm & 500gm Sodium Hydroxide Pellets Class 8 UN1823 PGII LTD Qty Class 8 UN1789 PGII LTD Qty 125gm & 500gm Potassium Nitrate 125gm & 500gm Copper Chloride Class 5.1 UN1486 PGIII LTD Qty Class 8 UN2802 PGIII LTD Qty Please let me know if you need any other information. I can be reached at 800-242-2042 extension 350 or email at rzellner@sciencekit.com Sincerely, Rupert Zellner Warehouse Manager West Coast: P.O. Box 5059 • San Luis Obispo, California 93403-5059 • Fax (805) 781-2559 Home Office: 777 East Park Drive a Tonawanda, New York 14150-6784 • (716) 874-6020 • Fax (716) 874-9572 http://sciencekit.com#