Fisher Scientific Company, LLC — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation 400 Seventh St., S.W. Research and Washington, D.C. 20590 Administration Special Programs JAN 3 0 2004 Mr. John G. Mayfield Ref. No. 03-0321 Manager, Dangerous Goods Transportation Fisher Scientific Company, LLC 2000 Park Lane Pittsburgh, PA 15275-1126 Dear Mr. Mayfield: This is in response to your letter dated December 17, 2003 requesting clarification on the classification of Bouin's Solution under the Hazardous Materials Regulations (HMR: 49 CFR Parts 171-180). Specifically, you would like a letter confirming your conclusions that a mixture consisting of 1.5% picric acid, 97 acetic acid, 19% formaldehyde, < 1% coloring agent, and approximately 79% water should be classified as "Corrosive liquid, acidic, organic, n.o.s. (formaldehyde, acetic acid), 8, UN3266, III." Under § 173.22 of the HMR, it is the shipper's responsibility to properly classify a hazardous material. This office generally does not perform this function. The definition of a corrosive material is found in § 173.136 of the HMR and procedures for packing group selection are found in § 173.137. Assuming that you have reviewed those sections and determined that your Bouin's Solution meets the definition of a corrosive material in packing group I and is assigned to the Corrosive liquid hazard class then the proper shipping name "Corrosive liquid, acidic, organic, n.o.s. (formaldehyde, acetic acid)" would be appropriate. However, the identification number that you provided in your letter, UN3266, is not consistent with the proper shipping name that you selected. UN3266 is the identification number for the proper shipping name "Corrosive liquid, basic, inorganic, n.o.s.". If your conclusions are accurate, then it is our opinion that the actual description would be "Corrosive liquid, acidic, organic, n.o.s. (formaldehyde, acetic acid), 8, UN3265, III." If you determine that a particular mixture of Bouin's Solution does not meet the definition of a corrosive material or any other hazard class, but it does present a risk during transportation, specifically air transportation, then it is our opinion that the basic description "Aviation regulated liquid, n.o.s. (formaldehyde), 9, UN3334, III" would be acceptable. However, if the acetic acid or picric acic contribute in any way to the hazards of the material they may be required to be included in basic 173.13% 030321 L23C#

Page 2description as part of the technical name (i.c., Aviation regulated liquid, n.o.s. (formaldehyde, acetic acid), 9, UN3334, III ot Aviation regulated liquid, n.o.s. (formaldehyde, picric acid), 9, UN3334, I). I hope this satisfies your request. Sincerely, Thas Arly Susan Gorsky Senior Transportation Regulations Specialist Office of Hazardous Materials Standards …#

Page 3DEC-17-2003 17:39 FROM-FISHER SCIENTIFIC QA +4124808605 T-148 P.002/003 F-363 Supko 2000 Park Lane Fisher Scientific Company L.L.C. Fisher Scientific § 172.101 Jonn.Mayfield@fisharsci.com Pittsburgh, PA 15275-1126 Tel: 412-490-8449 Classification Fax: 412-490-8930 December 17; 2003... Dr. Charles Ke 03-0321 fishersci.. " Office of Hazardous Materials Fechnology US Department of Transportation 400 Seventh Street S.W. Research and Special Programs Administration Washington; ĐC 20590-. Re: Bouins Solution Classification Dear Dr. Ke: Thank you for taking our call of this morning: In response to our conversation regarding the classification for primary as a tissue fixative: Fisher Scientific purchases this material from various vendors for resale. While Bouins Solution. we offer the following information. Bouins Solution is a product used in the medical industry maximum percentages are picric acid (trinitrophenol) at 1.5%, acetic acid at 9%, formaidehyde at 19%, one the various producers' exact percentages and components may vary, the primary ingredients with their requested; we have enclosed a copy of Mr. Mazzullo's Memorandum to Mr. William G. Wilkening dated June 2. coloring agent (which varies by supplier) at < 1% and water as the balance or approximately 79%. As 2000, which specifically states that mixtures of picric acid (1.3%) and water (98.7%) are not subject to the trinitrophenal wetred with not less than 30% water. We do not feel that the addition of the formaldehyde or We believe that the Bouins Solution mixtures should not be regulated as a 4.1, as is the classification for acetic acid would contribute to the activity of the trinitrophenol. The final product should not be classified as percentages of formaldenyde and acetic acid, we propose the classification for transporation as: either explosive or reactive:" However, we do think that the materials would fall under the HMR. Due to the Corrosive Liquid; Acidic; Organic; N:O:S: (formaldenyde, acetic acid). 8, UN3266, Ill to meet the definition of corrosive, we propose that the alternative classification for materials tested and found Given the possibility that some of these Bouins Solutions may not contain enough acetic acid or formaldehyde to be non-corrosive be: Aviation Regulated Liquid, N.O.S. (formaldehyde), 9, UN3334, III Do you agree with our classifications? Thank you for your time. If you have any other questions, please do not hesitate to contact me. Respectfully. lotS haull Manager, Dangérous Goods Transportation... Enclosure: 1#