Woodside Inc. — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation JUL 2 3 2003 Nashington, D.C. 20590 100 Seventh St., S.W Andrew Woodside Ph.D. Woodside Inc. Ref. No. 03-0174 300 Hanna Dr. Ponca City, OK 74604 Dear Dr. Woodside, applicabilite pose azad us Material gutter sardi cR Parts 171-180) to tricresyl phosphate, with less than 3 percent ortho isomer. classify a hazardous material. Under § 173.22, it is the shipper's responsibility to properly required to be verified by this office. Such determination are not However, "Tricresyl phosphate with more than 3 percent ortho isomer, PG II" is not an appropriate proper shipping name if your product 6.1, UN 2574, has less then 3 percent ortho isomer. states that a material shall be described by an appropriate Section 172.101 (c) (12) (i) proper shipping name listed in association with the correct for the material. If your material does not meet the criteria of hazard class, packing group, hazard zone, or subsidiary hazard a Division 6.1 and does not meet any other hazard class, it is not subject to the HMR. I hope this satisfies your request. Sincerely, Office of Hazardous Materials Standards | 13,22 030174#

Page 2InfoCutr BAH sor the atached Andrew Woodside Ph. D. email interp request $/13.132 Woodside Inc. Ponca City, Oklahoma 74604. 300 Hanna Drive Applicability 580-765-8683 03-0174 To Whom it May Concern, the following question: Per CFR 49 Section 105.20 "Guidance and Interpretations" I am requesting a formal response to Is tricresyl phosphate (UN 2574) containing less than 3% of the ortho isomer considered to be a hazardous material for shipping purposes? this is incorrect, please correct me and provide an explanation. This chemical called tricresy! Based on my chemical knowledge and my interpretation of the regulations in CFR 49, it is not. If phosphate is a lead scavenger for internal combustion engines. It has been used by piston technical grade of TCP. The technical grade of this chemical contains less than 1% of the ortho engine aircraft operators for fifty years. I plan to make a business of buying and re-selling the isomer which is the isomer that is considered highly toxic. The table in CFR 49, part 172 lists TCP than 3% of the ortho isomer is not considered hazardous and thus may be shipped without regard with greater than 3% of the ortho isomer as being hazardous. May I infer then, that TCP with less to the hazardous material regulations? Thank you for your formal guidance. Kind Regards, Andrew B. Woodside Ph.D.#