PPG Industries, Inc. — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation 400 Seventh St., S.W. Washington, D.C. 20590 Special Programs Research and Administration FEB 2:4 2004 Mr. Gordon W. Rousseau Ref. No. 04-0033 5448 Solway Drive Melbourne Beach, Florida 32951 Dear Mr. Rousseau: This responds to your February 23, 2004 letter on behalf of PPG Industries, Inc., concerning the transportation of calcium hypochlorite, hydrated, UN 2880, under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if calcium hypochlorite, hydrated, UN 2880, transported in 300- and 425-lb. fiber drums, is a forbidden material within the meaning of § 173.21 of the HMR. The answer is no. Notwithstanding that the self-accelerated decomposition temperature (SADT) of calcium hypochlorite, hydrated, UN 2880, in the drums is slightly less than 50 °C, the material is not forbidden under § 173.21 because the material is not likely to decompose under normal conditions of transport when shipped in accordance with applicable regulatory requirements. Under the HIMR, calcium hypochlorite, hydrated, UN 2880, is not subject to the controlled temperature provisions of § 173.21(f) when transported in the quantities and packagings specified in your letter. All applicable HMR requirements for shipping documentation, packaging, marking, labeling, placarding, and stowage and segregation must be met. Similarly, calcium hypochlorite, hydrated, UN 2880, is not a prohibited material or subject to temperature control requirements under the provisions of the International Maritime Dangerous Goods (IMDG) Code. Under both the HMR and the IMDG Code, calcium hypochlorite, hydrated, UN 2880, is subject to stowage provisions that require it to be stowed away from heat. I hope this information is helpful. Please let me know if you have questions or require additional information. Sincerely, Edward T. Mazzullo Director, Office of Hazardous Materials Standards 040033 |73.21#

Page 2Gorsky 3173.2/ GORDON W. ROUSSEAU Fobbidden Melbourne Beach, FL 32951 5448 Solway Drive Materials Tel. No. 321-951-3220 Fax No. 413-622-7627 04-0033 February 23, 2004 Edward T. Mazzullo, Director Office of Hazardous Materials Standards Research and Special Projects Administration Washington, DC 20590 U.S. Department of Transportation Re: Authorized Transportation of Calcium Hypochlorite Hydrated (UN2880) Pursuant to 49 C.F.R. Subchapter C Dear Mr. Mazzullo: I am writing on behalf of PPG Industries, Inc. (PPG). As discussed, PPG has long un- derstood that the transportation of UN2880 in 300 and 425 lb. fiber drums is authorized under the provisions of 49 C.F.R. Subchapter C. I should be grateful if you would confirm that PPG's interpretation of the relevant regulatory provisions is correct. It has been suggested that even though authorized by the package requirements of the Ib. drums is nevertheless "forbidden" by § 173.21(f) because the SADT of the product in those Hazardous Materials Table (HIMT), 49 CFR § 172.101, the shipment of UN2880 in 300 and 42: drum sizes is less than 50°C. (IMO documentation indicates that this SADT information was known as far back as 1980. According to information before the IMO and DOT it is clear that the critical temperature of the product in these drums is below 50°C. Information PPG in these drums is between 47°C and 50°C.) previously furnished to DOT confirms the earlier IMO information that the SADT of the product#

Page 3Germany and Japan to require temperature controls on UN2880. DOT surely would not have done so if the shipment of UN2880 in 300 and 425 lb. drums were forbidden by § 173.21(f). drums is not "forbidden" simply because the SADT threshold is below 50°C, and that UN2880 is Can you therefore please confirm that the shipment of UN2880 in 300 and 425 Ib. fiber not on account of § 173.21(f) subject to the controlled temperature provisions in 49 C.F.R. or the IMDG Code? Thank you for your assistance. Very truly yours, Gordon W. Rousseau#