Quaker Chemical Corporation — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department 400 Seventh St., S.W. Special Programs Research and Washington, D.C. 20590 Administration NOV - 4 2003 Ms. Kathryn F. Strang, CHMM Manager, Regulatory & Environmental Affairs Ref. No. 03-0243 One Quaker Park Quaker Chemical Corporation 901 Hector Street Conshohocken, PA 19428-0809 Dear Ms. Strang: This responds to your September 29, 2003, letter requesting clarification on the proper hazardous materials under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171- classification of a liquid containing water and sodium nitrite, as well as several other non- 180). Specifically, you ask whether you should classify the material as "Oxidizing Liquid, n.o.s., 5.1" or as an "Environmentally Hazardous Substance, Liquid, n.o.s., 9". Section 173.22 requires the shipper to properly class and describe the hazardous material in accordance with the HMR. This Office does not perform that function. If the sodium nitrite mixture you describe meets the defining criteria in Part 173 for a Division 5.1 Oxidizer, you may describe the material as "Sodium nitrite solution, UN 1500, PG III" or "Oxidizing liquid, 11.0.5. (sodium nitrite), 5.1, UN 3139, PG I, II, or III, "as appropriate." In addition, sodium nitrite is listed as a hazardous substance in Appendix A to § 172.101, List of Environmentally Hazardous Substances and Reportable Quantities, with a reportable quantity of 100 pounds. If the quantity of material being transported in one package meets or exceeds the reportable description. quantity for sodium nitrite, the letters "RQ" must be included either before or after the basic I hope this answers your inquiry. Sincerely, Wasn Shay Susan Gorsky Senior Transportation Regulations Specialist Office of Hazardous Materials Standards 172.101 030243 S8043000•#

Page 2Boothe Quaker $172.101 Proper Shipping Name 03-0243 September 29, 2003 Mr. Ed Mazzullo U.S. Department of Transportation Research & Special Programs Administration Office of Hazardous Materials Standards 400 Seventh Street, SW Washington, DC 20590 Dear Mr. Mazzullo: We are requesting a clarification of classification for an liquid that contains water, sodare mie as el a several other Moria as us ang ling 17. 1. or as an "Environmentally Hazardous Substances, Liquid, , n.o.s., 9". Any assistance that you can provide would be greatly appreciated. Sincerely, Katheys 7Stvang Kathryn F. Strang, CHMM Environmental Affairs Manager, Regulatory & Quaker Chemical Corporation One Quaker Park, 901 Hector Street, Conshohocken, PA 19428-0809 USA www.quakerchem.com T 610.832.4000 F 610.832.8682#