# Leak Location Services, Inc. — Hazardous Materials Safety Interpretation

- **operation:** document
- **citation:** 03-0277
- **title:** Leak Location Services, Inc. — Hazardous Materials Safety Interpretation
- **source type:** guidance
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** guidance
- **official:** true
- **published on:** 2004-02-05
- **effective on:** Not available
- **summary:** 03-0277 response to Leak Location Services, Inc. concerning 172.101.
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-interpretation-03-0277.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-interpretation-03-0277.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-interpretation-03-0277
- **source url:** https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2003/030277.pdf
**body:**

<<<PAGE 1>>>

•
•
of Transportation
U.S. Department
400 Seventh St., S.W.
Special Programs
Research and
FEB
5 2004
Washington, D.C. 20590
Administration
Mr. Daren L. Laine
President
Ref. No.: 03-0277
Leak Location Services, Inc.
16124 University Oak
San Antonia, TX 78249
Dear Mr. Laine:
•
This responds to your letter dated October 30, 2003, regarding the Hazardous Materials
Regulations (HMR; 49 CFR Parts 171-180), as they apply to Copper sulfate pentahydrate
shipped on passenger-carrying airlines. Subsequently, you sent a letter dated November 5, 2003,
to clarify your previous request for interpretation.
You stated that your company transports small quantities (less than 5 lbs.) of Copper sulfate
pentahydrate crystals (cupric sulfate, copper sulfate, etc.) in checked baggage on passenger-
carrying aircraft. The Copper sulfate pentahydrate is packaged in a 16-ounce wide-mouth plastic
bottle with a screw top and labeled "Copper Sulfate (CuSO, 5H,O) RQ=10 Ibs". The labeled
plastic bottle is placed inside a larger PVC container with sealed ends. The double container is
then placed inside a suitcase or fiberglass equipment case with other equipment. Your questions
are paraphrased and answered as follows:
Q1. Is this material (CuSO, 5H,O) regulated in either form as a hazardous material for
purposes of transportation under the HMR?
Al. Cupric sulfate is listed in the §172.101, List of Hazardous Substances, Table 1, Appendix
A, with a reportable quantity (RO) of 10 Ibs. Therefore, the material would be regulated
as a hazardous substance, as defined in § 171.8, if the quantity of Cupric sulfate, in one
package, equals or exceeds the RQ, and must be packaged and shipped as cargo as
specified in the HMR.
Since your company is shipping less than 5 lbs. per package, the Cupric sulfate does not
meet the definition of a hazardous substance, and provided your product does not meet the
definition of any other hazard class, it would not be subject to the HMR and not regulated
for purposes of transportation.
Q2.
The description in section 14 of the enclosed MSDS is "RQ, Environmentally hazardous
substances, solid, n.o.s., (Cupric sulfate)." Does the information shown mean we cannot
ship this material, and how do we complete Section 14 to continue to ship our product?

<<<PAGE 2>>>

A2.
If the material is a hazardous substance, it would be described as "RO, Environmentally
hazardous substances, solid, n.o.s., (Cupric sulfate), 9, UN3077, IT'and must be shipped
in non-bulk packaging in accordance with § 173.213. A MSDS may be used to satisfy
the emergency response information requirements specified in $172.602 of the HMIR.
However, the information on a MSDS is required by the Department of Labor's
Occupational Safety and Health Administration (OSHA), not the U.S. Department of
Transportation.
Q3.
Do we have to declare this material prior to flight, and can it be shipped without special
handling.
A3.
If the material is not a hazardous substance, and thus not a hazardous material, it would not
be subject to the HMR, and would not require special handling.
Although, it appears that your product may not be regulated, the issue of whether an airline may
deny your shipment is not under our purview. Each airline determines what is allowed on its
aircraft. Also, air carrier hazmat screening is conducted to comply with the Transportation
Security Agency's (TSA) security rules. You may wish to contact the TSA to make sure your
material is not considered a security risk.
•
I hope this information is helpful, If we can be of further assistance, please contact us.
Sincerely,
Dasa Dist
Susan Gorsky
Senior Transportation Regulations Specialist
Office of Hazardous Materials Standards

<<<PAGE 3>>>

18/38/2883 16:61
210-408-1242
LEAK LOCATION SUS
PAGE 01/09
LEAK LOCATION SERVICES, INC.
16124 UNIVERSITY OAK • SAN ANTONIO, TEXAS 78249 • (210) 408-1241 / FÁX (210) 408-1242 .
October 30, 2003
Mr. Edward Mazzullo
Engrum
Director of The Office of Hazardous Materials Safety
Washington, D.C
§112.101 AppA
Hazardous Substance
Fax:
(202) 366-3012
03-0277
Subject:
Transportation of Copper Sulfate Pentabydrate as Checked Airline Baggage
Dear Mr. Mazzullo:
I talked today with Mr. Michael Stephens of your office regarding the DOT regulations for
shipping copper sulfate pentahydrate (CuSO, 5Hl, O) on passenger airlines. As was discussed with
Mr. Stephens our company transports on a regular basis as checked airline baggage the following:
•
Copper sulfate crystals (Cupric sulfate);
Quantity shipped is less than 5 Ibs;
Packaged in a plastic container and labeled;
•
We also use an overpack type containex for the plastic container;
An MSDS data sheet accompanies the baggage;
This double package is placed in an equipment suitcase.
The airlines have recentiy stated that this material is a hazardous substance and must be
transported as such. We have also been questioned by TSA personnel. However, as we understand
the regulations, this material is not regulated or considered a hazardous material as long as we are
transporting less than 10 Ibs. Therefore, we are transporting this material ia an appropriate manner.
We request that The Office of Hazardous Materials Safety provide us with the proper
guidance for transporting copper sulfate pentabydrate, cupric sulfate, copper sulfate, eic. This
matorial is availablo ia crystal and powder forma from various suppliers. Specifically we request a
letter answering the following questions:
Is this material (CuSO, 5H, O) in either for regulated per DOT?;
Is this material a hazardous material for shipping purposes?;
Does the airline have cause for denying our shipment per the regulations?
How do we respond to Section 14 of the attached ZEP MSDS?
Does Section 14 mean we can not ship the material as we have in the past?
•
Do we have to declare this material prior to our flight?; and
•
Can this material be shipped as described without special bandling?;
www.leaklocationservices.com/results@leaklocationservices.com

<<<PAGE 4>>>

10/30/2003 16:01
210-408-1242
LEAK LOCATION SUS
PAGE 02/09
DOT-OHMIS
LLSI
October 30, 2003
Page 2 of2
We thank you in advance for your prompt response to our questions. If you have questions
about the this request, please contact the undersigned at (210) 408-1241.
Very truly yours,
Dawnsta
Daren L. Laine
President
enclosure:
MSDS - ZEP Root Kill II
MSDS - Tennessee Brand Copper Sulfate
cc:
John Andrews - SWA Safety Manager - (214) 792-6201
leaklocationservices.com results@leaklocationservices.com

<<<PAGE 5>>>

10/30/2803
16:01
218-408-1242
LEAK LOCATION SVS
PAGE 83/09
•
iT Matana Safety or hones
AMANDING AROUN ORMATOR
ENFORCER Products, Inc.
P.O. Box 1060
Section 1. Chemical Product and Company Identification
Cartersville, GA 30120
1-888-805-HELP
Product name Root Kill IT
Product Code
ZDCR-2C
Formula No.
Not available,
Dato of Issue
05/02/02
Version 1.0
Emergency
talophone
For MSDS Information:
number
Compliance Services, 104352 1680
INFOTRAC, 877 SAI 2016 (Calls Recorded)
Fore Medical Emergency: Toll Free
or a Transportation Emergency: Toll Fre
HEMTREC, 800 424 9300 (Calls Recordo
Prepared by
1420 Scaboard Industrial Bivd.
Acuity Specialty Products Group
Atlanta, GA 30318
Section 2. Composition, Information on Ingredients
Name of Hazardous inpredients
CAS *
1 Me by Weight,
Exposure Limite
1) Copper sulfate pontabydrato
7758-99-8
90-100
OSHA PEL Z2 (United States).
TWA: 1 mg/m Form: Dusts and Mists
Section 3. Hazards Identification
Acute Effects
Routes or kantry Agerbed through skin. Eye contact. Antalation.
Skün Hazardous in case ofskin contact (imitant, scositizes). Skin inflammaliun is characierized by itching,
Eyes Sereraly initating to the eyes. Eye expoure may cause reversible eye injury.
HIMES
Inhalasion Hazardous in case of inhalation. Inhalation of dust will produce irritation to the respiratory tract,
scaling, reddening, or, occasionally, blistering. Prolonged exposure may result in skin bums.
3
Ingestion Toxic if swallowed. Ingestion may cause severe gastric disturbances, burning in throat, and circulatory
characterized by buring, sneezing and coughing.
failure.
Chronic Blees The substance is toxic to kidneys and the nervous syrem. Repead or prolonged exposure Personal Protation
Carcinogenic Effects Not availablo.
to the substance can produce target organs damsge.
E
Sec Iox/cological Information (section 11)
Section 4. First Aid Measures
Ingestion
Section 5. Fire Fighting Moesures
Flammability Not applicable.
Flash Point Not applicable.
Flammable Limits Not applicable
Fire Hazard Not applicable.
Fire-Fighting Procedures Notapplicable.
•
Conned on Nax Page

<<<PAGE 6>>>

10/30/2003 16:01
210-408-1242
LEAK LOCATION SVS
PAGE 84/09
•
Section 6. Accidental Refease Measures
Spill Clean up
Section 7. Handling and Storage
Avoid contact with eyes, skin and clothing. Do not ingest. Wash thoroughly after handling.
Keep corrainer dry and tightly closed. Keep container in a cool, wall-ventilated area. Store between 40°F and 120°F.
Personal Protection
Section 8. Exposure Controls, Personal Protection
Splashi goggles.
Protective Clothlog (Pictograms)
Rcspiratory.. Wear appropriate respirator when ventilation is inadequate.
Wear coveralls or long sleeved shir and long trousers.
Section 9. Physical and Chomical Properties
Physical State
Solid. (Crystals.)
Color
Specific Gravity
Bolling Point
apor Pressur
Odor
Blue.
Odoriess.
They lie po alde 228 (Water = 1)
Tapor Densics
Not applicable.
Not available.
VOC (Consumer)
Solubllity
• 0 (s/).
Easily soluble in cold water, hot waler.
Evaporation Rate
Not available.
Section 10. Stability and Reactivily
Stabllity aud Reactivity
Incompatiblity Reactive with alkalis and phosphates.
The product is stable.
Hazardous Decomposition Products Not applicable.
Hazardous Polymerization Notavailable.
Section 11. Toxicological Information
Toxicity tu Animals
Chront Effeces on Humans
Not available.
ORAL (LDSO):
Section 12. Ecological Information
Ecotoxicity
Biodegradable/OECD
Not available,
Not available.
Section 13. Disposal Considerations
Waste laformation
Waste Stream
Not aveilable.
Waste must be disposed of in accordance with federal, state and local environmental control regulations.
Consult your local or replonal authorides.
Section 14. Transport Information
Proper shipping name
Rp-Hold Colly Dad
BEN - 800-313-8439
ex 642/
IDG Classification
TDG Class 9.2: Envizontentally hazardous material.
Section 15. Regulatory Information
U.S. Foderal Regulations
SARA 313 roxic chemical notification and release reporting: Copper compounds
Clean Water Act (CWA) 311: Copper sulfato pentabydrate
Clean air act (CAA) 112 regulated toxic substances: No products were found.
State Regulations
Califomia prop. 65: No products were found.
WHMUS (Canada)
Gonated, on Next Rage

<<<PAGE 7>>>

10/30/2003 16:01
210-408-1242
LEAK LOCATION SVS
PAGE 05/09
ASTRO PRODUCT CODE # 25004
Griffin
MATERIAL SAFETY DATA SHEET
Page 1 of 5
Tennessee Brand Copper Sulfare (CUSO, 0M,0)
DATE PREPARED: JUne 27, 1998
1. CHEMICAL PRODUCT AND COMPANY IDENTIFICATION
FRODUCT IDENTIFICATION
Product Nama(s):
Tennesser Brand Copper Sulfare Crystals
Tennessee Brand Copper Sulfare Feed Grade
Tennesses Brand Coppor Sulfate Instant
Synonyms:
Tennesses Brand Copper Sulfate Industrial Grade
Crystals, Coppur Suttate Granular Crystals, Cappor
Copper Sulfaté Lato Grystals, Copper Sulfate Medium
Sulfate Snow Crystals, Copper Sulfare Supertine Crystals,
Sultata Faud Gracie, Bluostone, Bhe Vitrial
CoppEr Sufface Powdered instant Bluestono, Copper
•
HAZARD CLASSIFICATION (0-minimal, 1-sfignt, 2-modarara, 3-serioua, 4-gavare)
NFPA:
HEALTH-2 FIRE-O REACTIVITY-O
MANUFACTURER
Address:
Company Name:
Griftin Corporation
0 Box 1847, Rocky Ford Roa
aldosta, GA 31603-184
HEMPREC
mergency Phone d
(800) 424 9300
(800) 237 1854
2.
COMPOSITION/ INFORMATION ON INGREDIENTS
Compar one a Paralydiate
7758-98-7
OSHA PEL
An one dust or mis ere are proproar or not hazardous.
HAZARDS IDENTIFICATION
EMERGENCY OVERVIEW
Praduct is toxic orally but not dormally. It is a skin sensinizer and skin iricant it is
corrosive to the eyes.
POTENTIAL HEALTH EFFECTS
Inhalation:
Copper sulfare is a akin iritant and sensitizer including
Eye Irritation:
Skin Irritation:
Skin iritant and sensitizer especially to some Individuals.
Ingestion:
Skin Absorption:
Not toxic dermally.
toxicity. Copper sulface may induce severe gastroenteric
Moderately taxic in human orally. High intraparitones!
and hemorrhagos). Prostration, anurla, hematuria, anemia,
distress ivomiting, gastraanseria pain, and loaal corrosion
increase in white blood cells, coma, respiratory aifficulties
and circulatory failure.
Chilin Caboration • PO B0X :947, Macky Ford Road, Valdosca, GA 31603-1847 • 18001 225-TE6a"

<<<PAGE 8>>>

10/30/2003 16:01
210-408-1242
LEAK LOCATION SVS
PAGE 86/89
ASTRO PRODUCT CODE # 25004
Griffin
MATERIAL SAFETY DATA SHEET
Tennessee Brand Copper Sulfare (CUSO, 5H,0)
Page 2 of 5
DATE PREPARED: June 27, 1995
Chronic:
umans which affects the metabolic and excretan
opper sulfate is reported to havo systemic affects i
functions of the liver and kidney.
4.
FIRST AID MEASURES
Inhalation:
• respiration preferably mouth-to-mouth. Get medical
Remove victim to fresh air. If not breathing, give artificial
Eye Contact:
attention immediataly.
of chemical renalns (at Ieast 15 - 20 minutes). Get
Hold eyelids open and flush with water, until no evidonce
Skin Contect:
Remove contaminated clothing and shoes. Wash with
medical arrantion immodiazely.
remain leproximately 1-20 minutes medical
Ingestion:
attention.
Drink i to 2 glasses of water and induce vomiting by
couching back of throat with finger. Do not induce
vomiting or give anything by moush to an unconscious
Nate to Physician:
gastric lavage. Mexaure against circulatory shock,
Probable mucosal damago may contraindicato sto use of
person. Get medical attention.
respiratary depresaion and convulsion may be noodod.
5.
FIRE FIGHTING MEASURES
-
Flammable Limits:
Flash Point & Method;
Not applicable.
Auroignition Temperature:
Not applicable.
Not applicadle.
FIRE FIGHTING HAZARDS & PROCEDURES
Ganeral Hazard:
Extinguishing Mecia:
Naglisible fire hazard when exposed to heat or flame.
combustion. If storad with other combuatible products, use
Capper sulfare done not bum, nor will it aupport
Fire Fighting Instructions:
water, CO, or dry chemical.
Avoid contact with molton product to prevant serious
Fire Fighting Egulament:
burns.
Wear protective clothing and soll-contained breathing
Hazardous Cambustion
apparatus.
Producta:
used, it will sclubilize the CuSO, -SH,O, and care shauld be
If dry heated above 600°C, SO, is evolved, If water in
taken ta keep such warer due of sinaams or other bodies of
water.
6.
ACCIDENTAL RELEASE MEASURES
Weer prorective clothing. Sweep up and placa in an aporopriare chemical waste container for
disposal.
Orin conorason 70 Box 1729. Rocky Ford Rese. Valdria, at 31805-1867 - 18001 287-1456

<<<PAGE 9>>>

10/30/2003 16:01
210-408-1242
LEAK LOCATION SVS
PAGE 07/09
ASTRO PRODUCT CODE # 25004
Griffin
MATERIAL SAFETY DATA SHEET
Pega 3 of 5
Tennessee Brand Copper Sulfare iCuSO, "5H,0)
DATE PREPARED: June 27, 1995
HANDLNG ANO STORAGE
Storaçe Tamperature:
Ganeral Information:
Not available.
reach of children.
Store in a clean, dry area. Keep this material out of the
EXPOSURE CONTROLS! PERSONAL PROTECTION
PESTICIDE APPLICATOAS & WORKERS
produst for Agricuitural Use Requirementa in accordance with the EPA Worker Proraction
These workers must refer to the Product Label and Cirections For Uon attached to the
MANUFACTURING. COMMERCIAL BLENDING, & PACKAGING WORKERS
Standard 40 CFR part 170.
Ventlation:
Control enclosed spaces with adequate yantilation to
mo/m".
ravent exceedance of ACGIH TLV or OSHA PEL (1
Respiratory Protaction:
In enclosed spacas where the TLV or PEL may be
respirator.
excorded, wear NIOSHIMSHA appraved dusz or mist
Eve Protectior:
Wear protective eyewear to prevant contact with this
Protective Clothing:
substance,
shirt and long pants, waterproof gloves and shoes plus
Applicarors and other handiers must wear long-steeved
ocks.
9.
PHYSICAL AND CHEMICAL PROPERTIES
Vapor Density (Air- 1):
Vapor Pressure:
7.3 mg Ha @ 25°C.
Specifie Gravity:
Not determined.
in Busyd Acetate = 11:
Evaporation Raro
Solublicy in Water (% by wr.): 22.37 @ 0°C, 117.95 @ 100°C.
Ner determined.
pH (596 soln.):
Meling Point:
Boiling Point (760 mm Hg):
-5 HO @ 150°C.
Odor:
No odor.
4H,0@110°C.
Physical State:
Color:
Blue.
Crystals or powder.
10.
STABILITY AND REACTIVITY
Incomparble Materials:
General:
This material is stablt under normal conditions.
Nane known. Product is highly soluble in water, but does
Condidone to Avoidi
not react with the water.
Hazardous Decomposition:
Excessiva heat.
None at normal process temperatures and pressures. It dry
Hazardous Polymorization:
Will not accur.
heated above 1100°F 1600°C) 50, may be relaased.
- Gritin Corporation a F0 Box 1547, Aocky Ford Road, Veidoria, GA 37603-7847+16007 25B5E

<<<PAGE 10>>>

10/30/2003 16:01
210-408-1242
LEAK LOCATION SVS
PAGE 08/09
ASTRO PRODUCT CODE # 25004
Griftin
MATERIAL SAFETY DATA SHEET
Pape 4 of 5
Tennessee Brand Copper Sulfare (CuSO, 5H,01
DATE PREPARED: June 27, 1995
11.
TOXICOLOGICAL INFORMATION
ACUTE
Inhalation:
irritation of the mucous membranes.
Acure intalation LEss > 1.48 mg/Lair. May cause
Eye imitation:
Skin Absorption:
Skin Irritation:
CHRONIC:
Ingestion:
Special Health Effacts:
12.
ECOLOGICAL INFORMATION
ECOTOXIITY (coppor sulfate pentatsydrare)
Tast Type
Speciat
Value
Bluegill
1.5 m97
Aquatic LOgo
Aquatic ECo
Rainbow Trout
Daphnia magne
0.182 mg/L
0.17 miL
13.
DISPOSAL CONSIDERATIONS
regiscared transporters.
Comply with appropriato disposal regulations, Landfit aolids at permitted stes. Use
14.
TRANSPONT INFORMATION
DOT (Departmert of Transportation)
PROPER SHIPPING NAME:
RO, Environmentally Hazardoua Subarances, Solid,
HAZAFID CLASS:
9
N.O.S. (Cupric Sulfata Pentabydraca) 9, UN3077, 11!
IDENTIFICATION NUMBER:
RQ:
10 (bs.
UN3077, Ill
15.
REGULATORY INFORMATION
TSCA;
All product components are on the SCA Chemical
CERCLA:
Inventory.
RQ - 10 Ibs. IThe Reportable Quantity for Cupila Sultase,
FDA:
•
CAS 47758-98+7, according to 40CFR 302.4)
This product is Genarally Racognized as Safe (GRAS) as i
race mineral for Ilvestock when used in accordance with
This product is Ganorally Rocoonizad as Safe (GRASI aS
good management practices.
when used in food wrap paper and paperboard products.
Gillia Copardion Pox 1647, Rocky Ford Road, Vacoata, LA J803-1647 (300 235-155
•

<<<PAGE 11>>>

10/30/2003 16:01
210-408-1242
LEAK LOCATION SVS
PAGE 09/09
ASTRO PRODUCT CODE # 25004
Griffin
MATERIAL SAFETY DATA SHEET
Page 5 of 5
Tennessee Brand Copper Sulfate (Cus0, 5H,0)
DATE PREPARED: Juno 27, 1995
SARA TITLE I
313 Roportable Ingrediants:
Ther d and Tier Il:
Copper 25.2%.
For R:
10,000 Ibs.
Asportable.
16.
OTHER INFORMATION
REVISION SUMMARY
•
THE INFORMATION IN THIS MSDS RELATES TO THIS SPECIFIC MATERIAL. IT MAY NOT BE
IN ANY PROCESS. IT IS THE USERS' RESPONSIBILITY TO SATISFY THEMSELVES AS TO
VALID FOR THIS MATERIAL IF USED IN COMBINATION WITH ANY OTHER MATERIALS OR
PARTICULAR USE.
THE SUITABILITY AND COMPLETENESS OF THIS INFORMATION FOR THEIR OWN
Gatin Carponson • PO Box 1977, Hocky Ford Hood, Valdosra GA 71603-1847 - 4001 2871255

<<<PAGE 12>>>

11/05/2003 17:49
210-408-1242
LEAK LOCATION SUS™
PAGE 01/06
LEAK LOCATION SERVICES, INC.
16124 UNIVERSITY OAK • SAN ANTONIO, TEXAS 78249 • (210) 408-1241 / FAX (210) 408-1242
November 5, 2003
Engrum
$172.101 App.A
Mr. Edward Mazzullo
Hazardous Substance
Director of The Office of Hazardous Materials Safety
03-0277
Washington, D.C
Fax:
(202) 366-3012
Subject:
Transportation of Copper Sulfate Pentahydrate as Checked Airline Baggage
Dear Mt. Mazzullo:
I wist to clarify our letter of October 30, 2003. As stated, Leak Location Services, Tac. bas
a requirement to transport small quantities (less than 5lbs) of copper sulfate pentalydrate
(CuSO, 5H,O) in checked airline passenger baggage. Copper sulfate is a salt that is used for various
applications including a dietary supplement for livestock, plant root remover for sewer lines, and
as we use as an electrolyte when making electrical measurements. The copper sulfate pentahydrate
is packed ia a 16-ouace wide-mouth plastic bottle with a screw top and labeled:
Copper Sulfate
(CuSO, • 5H,O)
RQ = 10 Ibs.
Causes irritation to eyes, skin and respiratory tract.
Harmful or fatal if swallowed.
The labeled plastic bottle is placed inside a larger PVC container with sealed ends. The
double-container is then placed inside a suite case or fiberglass equipment case with orher
equipment. The material is then shipped as passenger baggage when LLSI field personnel travel to
a project site:
The airline's concena is that this is a hazardous substance. In addition, the airline has stated
that this is a "corrosive" material and if spilled would damage the aircraft. As we understand the
regulations this material is not regulated or considered a hazardous material as long as we are
transporting less than the reportable quantity of 10 Ibs. Also, the "corrosive" warning for this
material is listed as a health warning and refers to a "corrosive" that is harpaful to the eyes, skin, and
respiratory tract and not a "corrosive" for metal parts.
www.leaklocationservices.com/results@leaklocationservices.com

<<<PAGE 13>>>

11/05/2003 17:49
210-408-1242
LEAK LOCATION SVS
PAGE 02/06
DOT-OHMS
LLSI
November 5, 2003
Page 2 0f2
We filly understand and appreciate the airlines concern for passenger safety and the safety
of their aircraut. We are also aware that the airlines wust follow aud comply with FAA regulations
tor the transportung of hazardous materials. However, we do not believe the copper sulfate
pentahydrate (CuSO,-5H,O) in the quantities we transport should be considered a hazardous
material per DOT guidelines. Furthermore, we feel we are following OSHA and DOT regulations
when we tratsport, store, aad handle this material and are transporting this material in a safe and
responsible manner.
Therefore, we request that The Office of Hazardous Materials Safety provide us with the
proper DOT guidaace for transporting copper sulfate pentabydrate (CuSO,-SH,O) as checked
baggage on passenger aircraft. We thank you in advance for your prompt response to our questions.
It you have questions about the this request, please contact the undersigned at (210) 408-1241.
Very truly yours,
Dawn Saw
Daren L. Laine
President
John Andrews - SWA Safety Manager - (214) 792-4086
attachment:
C.J. Martin Company - MSDS for Copper Sulfate Pentahydrate
leaklocationservices.com
results@leaklocationservices.com

<<<PAGE 14>>>

11/05/2003 17:49
218-408-1242
LEAK LOCATION SUS
PAGE 03/06
MATERIAL SAFETY DATA SHEET
Revised: 02/16/99
SECTIONI - IDENTIFICATION OF PRODUCT
MANUFACTURER'S NAME:
2739 PASADENA BLVD.
C.J. MARTIN COMPANY
PASADENA, TX 77502
PRODUCT NAME:
MARTIN'S COPPER SULFATE CRYSTALS
EMERGENCY TELEPHONE:
(800) 424-9300 - CHEMTREC
CHEMICAL NAME:
Copper Sulfate Pentahydrate
G.A.S. NAME:
See Section VII
CA.S. NUMBER:
See Section VII
CHEMICAL FORMULA:
N/A
MOLECULAR WEIGHT:
N/A
CHEMICAL FAMILY:
NIA
D.O.T. HAZARD CLASS:
9 (misc. hazardous materiale)
D.O.T. SHIPPING NAME:
ORM-D, Consumer Commodity
SECTION II - PHYSICAL DATA
ODOR:
odorless
MELTING POINT:
110 degrees Celsius
APPEARANCE:
transparent blue crystals
PARTICLE SIZE:
NIA
LBS/GAL:
NIA
CLOUD PT:
COLOR (G-H):
NIA
PERCENT VOLATILE:
BOILING POINT:
150 deg. Celsius
EVAPORATION RATE:
NA
VAPOR PRESSURE:
N/A
FLASH POINT:
NIA
VAPOR DENSITY:
N/A
SPECIFIC GRAVITY:
N/A
BULK DENSITY (FLUFFED):
N/A
BULK DENSITY (SETTLED):
NIA
REFRACTIVE INDEX:
NA
SOLUBILITY (OIL):
NIA
SOLUBILITY (WATER):
30 degrees Celsius
24.3 grams/100 grams at
SECTION III - PHYSICAL HAZARDS
STABILITY:
Stable
CONDITIONS TO AVDID:
High heat, Reducing agents
INCOMPATIBILITY (Materials to avoid): Contact with magnesium metal may generate dangerous levels of hydrogen gas.
HAZARDOUS DECOMPOSITION PRODUCTS: A emperatureres Celsius sulfur dioxide may be evoived, none at normal process
Page -1-

<<<PAGE 15>>>

11/05/2003
17:49
210-408-1242
LEAK LOCATION SVS
PAGE
04/06
•
MATERIAL SAFETY DATA SHEET
HAZARDOUS POLMERIZATION:
Will not accur.
Page -2-

<<<PAGE 16>>>

11/05/2003 17:49
210-408-1242
LEAK LOCATION SVS
PAGE 05/06
MATERIAL SAFETY DATA SHEET
•
SECTION IV - FIRE & EXPLOSION HAZARD DATA
FLASH POINT (METHOD USED):
NIA
FLAMMABLE LIMIT (LOWER):
N/A
FLAMMABLE LIMIT (UPPER):
N/A
FIRE EXTINGUISHING MEDIA:
Does not burn or support combustion.
SPECIAL PROCEDURES:
water. Avoid direct water stream on moltan material (splattering occurs).
Use extinguisher media for surrounding fire, CO2, dry chemical o
UNUSUAL FIRE/EXPLOSION HAZARDS:
Heated above 110 degrees Celslus will melt and flow. Sealed containers may
when dissolved in water, contact with magnesium metal may evolve hydroge
upture when heated due to release of water from crystals. Materlal Is acldi
gas. Anhydrous cupric sulfate formed on water loss (white color). Anhydrous
degrees Celslus decomposes to cupric axide and sulfur dioxide.
At temperatures greater than 600
SECTION V - HEALTH HAZARD RATA
ACUTE:
Corrosive:
Harmful or fatal if swallowed
Causes eye damage and irritation to the skin and mucous membranes.
CHRONIC:
Very rare, except In Individuals with Wilson's disease.
SIGNS AND SYMPTOMS OF EXPOSURE: Locallzed skin discoloration, itching, eye irritation, ulceration of nasal septum may occur,
repeated or prolonged skin contact may cause dermatitis.
MEDICAL CONDITIONS GENERALLY AGGRAVATED BY EXPOSURE: Wilson's disease (Retains and stores copper excessivaly).
CHEMICAL LISTED AS CARCINOGEN: No
SECTION VI - SPECIAL PROTECTION
EYE PROTECTION:
Chemical goggles in splash hazard areas.
RESPIRATORY PROTECTION:
NIOSH/MSHA approved respirator for toxic dusts.
VENTILATION:
Yes
LOCAL EXHAUST:
Yes
PROTECTIVE GLOVES:
Rubber
OTHER PROTECTIVE EQUIPMENT:
Eye wash station should be available in work areas.
WORKHYGENIC PRACTICES:
Observe good personal hygiene practices. Wash hands before eating.
SECTION VII - HAZARDOUS COMPONENTS OF MIXTURES
MATERIAL
PERCENT
Copper Sulfare Pentahydrate, CAS # 7758-99-8
99%
Inent Ingredients: *
Inert ingredients may contain: Cupric Sulfate (CuSO4)
Blue Vitriol
1%
Page -3-

<<<PAGE 17>>>

11/05/2003 17:49
210-408-1242
LEAK LOCATION SVS
:
PAGE 06/06
MATERIAL SAFETY DATA SHEET
SECTION VII - EMERGENCY & FIRST AID PROCEDURES
IF INGESTED:
May be fatal if swallowed. Do not induca vomiting. Get medical attention.
IF INHALED:
Move to fresh air. Administer CPR if necessary.
•
IF ON SKIN:
-lush with large amounts of water at least 15 minutes. Remove contaminated clothing. Get medica
attention if iritation persists.
IF IN EYES:
atention trition pens alter for at least 15 minutes. Hold yolas open during fushing. Cet modical
Treat most urgent symploms first cessation of breathing, eye injury, skin contact, shock, in all cases seek medical assistance.
SECTION IX - SPILLAGE OR LEAKAGE PROCEDURES
alts and dispose of In an approved landfill. Prevent accidental entry of solution into streams and other water bodie:
weep up crystals, vacuum is preferred. If spilled solution is in a confined area, introduce lime or soda ash to form insoluble coppe
SECTION X - WASTE: DISPOSAL METHODS
Contact appropriate local, state and federal officials.
SECTION XI - ADDITIONAL PRECAUTIONS
Do not contaminate water, food, or feed by storage or disposal.
Storage:
Store in closed containers in a cool, dry, well ventilated place away from heat sources and reducing agents.
Use good housekeeping practices to prevent dust accumulation.
Contalner Disposal:
Do not reuse container. Securely wrap original continer in several layers of newspaper and discard in
trash.
Envlronmental Hazards: This product is toxic to fish. Direct application of Copper Sulfate to water may cause a significant reduction
in populations of aquatic invertebrates, plants and fish. Do not treat more than one-half of lake or pond a
treatments for oxygen levels to recover.
one time in order to avoid dapletion of oxygen from decaying vegetation. Allow 1 to 2 weeks betwear
recommended on this label especially in soft or acid waters. However, fish toxicity generally decreases
ure the a dose cat safe fish an. Pane Agency before applying this product to pubie waters.
Permits may be required before treating such waters.
SECTION XII - COMMENTS
•
•
Page -4-
- **truncated:** false
- **body characters:** 28417
