Huntsman Corporation — Hazardous Materials Safety Interpretation

Page 1U.S. Department Research and of Transportation 400 Seventh St., S.W. Washington, D.C. 20590 special Program ldministration DEC 1 9 2003 Mr. Philip Abraham Huntsman Corporation Ref. No. 03-0288 3040 Post Oak Boulevard Houston, Texas 77056 Dear Mr. Abraham: This responds to your November 6, 2003, letter requesting clarification on the hazard class of your product under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you request verification that the hazard class assigned to your product "Jeffamine D-2000, polyoxypropylenediamine" is correct. According to your letter and enclosed test data, your product is currently described as "Corrosive liquids, toxic, n.o.s.(polyoxypropylenediamine), 8, UN 2922, PG II" with a subsidiary Division 6.1 toxic hazard for oral toxicity. You state that based on two separate tests, your product meets the defining criteria in the HMR for Class 8 corrosive liquid as the primary hazard class with a subsidiary Division 6.1 toxic hazard for oral toxicity. However, using your Huntsman test data, your competitor has classed the same product as a Class 8 corrosive liquid with no subsidiary Division 6.1 toxic hazard for oral toxicity. You request verification on the correct hazard class. Under § 173.22, it is the shipper's responsibility to properly class and describe a hazardous material for shipment. This Office does not ordinarily perform that function. However, based on the information and test data provided in your letter, it is the opinion of this Office that your product is properly classed as a Class 8 corrosive liquid at the packing group Il level with a subsidiary Division 6.1 toxic hazard for oral toxicity. I hope this answers your inquiry. Sincerely, Jia Drag Susan Gorsky Senior Transportation Regulations Specialist Office of Hazardous Materials Standards 173.132 030288#

Page 2Boothe HUNTSMAN Page 1 of 2 $ 173.132 Definition 03-0288 November 6, 2003 Mr. Edward Mazzullo, Director Office of Hazardous Materials Standards (DHM-10) Research and Special Programs Administration U.S. Department of Transportation Washington, DC 20590-0001 400 Seventh St., SW Re: Petition for a ruling to provide an appropriate transport classification for product JEFFAMINE® D-2000 Dear Mr. Mazzullo, The combined Huntsman companies constitute the world's largest privately held of global industries including chemicals, plastics, automotive, aviation, footwear, paints chemical company. The operating companies manufacture basic products for a variety and coatings, construction, technology, agriculture, health care, textiles, detergent, personal care, furniture, appliances and packaging. JEFFAMINE ® D-2000 polyoxypropylenediamine is a member of a family of polyamines, manufactured by Huntsman, having repeated oxypropylene units in the backbone. This product is a difunctional primary amine with an average molecular weight of approximately 2000. Its amine groups are located on secondary carbon atoms at the ends of an aliphatic polyether chain. There were two separate Acute Exposures Oral Toxicity studies done in 1991 and 1993 on this material by an independent testing facility. These tests determined that tests consistently resulted in single oral dose LDso values in rats to be less than 0.5 g/ JEFFAMINE ® D-2000 polyoxypropylenediamine is considered toxic if swallowed. Both kg. The Draize score for skin, irritation in rabbits is 8.0/ 8.0 and the product has been determined to be corrosive to the skin by the DOT 4-hour test. Based on the test data, Huntsman currently classifies JEFFAMINE® D-2000 for shipping as a "Corrosive Liquids, Toxic, N.O.S." , and a Technical Name given as polyoxypropylenediamine. The Primary Hazard is Class 8 and a Subsidiary Hazarc Class 6.1, with UN 2922, and a Packing Group Ill designation for packaging. 3040 Post Oak Boulevard • Houston, Texas 77056 • 713-235-6000 • Fax 713-235-6416 HUNTSMAN CORPORATION#

Page 3Page 2 0F2 A Huntsman's competitor also sells this polyoxypropylenediamine brand. They have concluded from the same Huntsman test data, that the oral toxicity value is obtained primarily due to the effects of corrosion on the internal organ tissues of the animals rather than a secondary oral toxicity hazard of the material. Therefore, they have been marketing and shipping this material with only a Corrosive hazard designation. do not influence its oral toxicity hazard. However, Huntsman asserts that the tests indicate the corrosive agents in this product believes that the omission of Toxic hazard from the competitors shipping classification Based on Huntsman developed information, which is publicly available, Huntsman for this material may result in an increased risk of adverse health effects from accidental exposures to this product. Huntsman petitions your office to review the enclosed test data and MSDS for JEFFAMINE® D-2000 and provide a ruling on the appropriate transport hazard classification for this product. Huntsman believes that the enclosed test data will corroborate Huntsman's assertion that the corrosivity of this material has minimal impact on the oral toxicity of the product. If you need further clarification on the data provided, then please don't hesitate to contact me. Sincerely, alie Ande Philip Abraham Huntsman LLC Hazardous Materials Specialist 3040 Post Oak Boulevard Houston, Texas, 77056 Telephone: 713-235-6025 Enclosures: 1). 2). Test data -1991 Test Summary 3). 4). Test data - 1993 MSDS#