Ray-Vin.Com — Hazardous Materials Safety Interpretation

Page 1U.S. Department Research and of Transportation Washington, D.C. 20590 400 Seventh St., S.W. speciai Programs Administration OCT 2 2 2003 Mr. Raymond V. Brandes Ref. No. 03-0179 1844 Mt. Cello Rd. Ray-Vin. Com Marianna, EL 32448-5365 Dear Mr.. Brandes: This is in response to your letter dated July 8, 2003 and subsequent telephone conversation with a member of my staff, concerning the regulation oi calcium carbide pursuant to the Your questions are paraphrased and answered as follows: Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Q1. Must calcium carbide (Division 4.3, UN1402, Packing Group Wet" placard? II), shipped as a limited quantity, 'display a-"Dangerous When A1. Division 4.3 solids in Packing Groups, Il and III are excepted No... Section 173.151 (d) states that limited quantities of from labeling, unless offered for transportation or contained in inner packagings not over 0.5kg (1.1 pound) net state that Division 4.3 solids in Packing Group II must be capacity each packed in strong outer packagings. 02. If a shipment qualifies as a limited quantity per exceptions in 173.151(d), is it still a hazardous material? A2. Yes. 03. If a shipment qualifies as a limited quantity per aircraft? exceptions in 173.151 (d), can it be loaded on passenger A3. As shown in the Hazardous Materials Table (S 172.101), calcium carbide in Packing Group II is not forbidden from package is limited to 15 kg. being loaded on passenger aircraft, but the net quantity per Section 173.151 (d) states that limited quantities of Division 4.3 solids in Packing Groups LI and III are excepted from labeling as long as it is not offered for transportation or transported by aircraft. This 173.151 030179#

Page 2language does not preclude the material from being loaded on is being offered for transportation or transported by air that passenger aircraft, but it does require that if the material it comply with the appropriate labeling requirements for packaging Division 4.3 Packing Group II materials. requirements specified in 173.27 apply to shipment In addition, by aircraft. 04. What, if any, requirements are there for labeling the internal package? outside of the package. A4. The required labels and markings must be displayed on the I hope this satisfies your request. Sincerely, Ifansportation Regulations Specialist Office of Hazardous Materials Standards#

Page 3BAH $172.101 Ray-Vin.Com RAY-VIN.COM Marianna, FL 32448-5365 1844 Mt. Cello Rd §173.151 www.ray-vin.com 8 July 2003 Exceptions Interpretation Request 03-0179 Department of Transportation RSPA Attn: Director - Office of Hazmat Standards 400 7' St, S.W. Washington, DC 20590 Dear Director, I have researched this mater on the DOT web site and have come to these conclusions regarding shipping calcium carbide. Would you be so kind as to confirm or deny my findings? sted in paragraph "D" of section 173.151, does not have to be labeled with the "dangerous when we ) Calcium carbide (dangerous when wet) in packaging group II, not weighing over 0.5kg, per exceptior placard? 2.) When the shipment qualifies as described in the first statement, is it still a hazardous material? 3.) When the shipment qualifies as described in the first statement, can it be loaded on passenger aircraft? 4.) What, if any, requirements are there for labeling the internal package? has a foam gasket. Additionally we would tape the cap to prevent it from unscrewing and this would all be We would like to ship approximately 4 ounces of the material in a plastic (hdpe) bottle with a screw lid that placed in a zip-lock bag. Sincerely, Karmad Mande Raymond V. Brandes Phone: 850-482-7562 Email: rvb@ray-vin.com#