Chemical Lime Company — Hazardous Materials Safety Interpretation

Page 1of Transporation U.S. Department 300 Sevanth Street, S.W. Washington, D.C. 20590 Pipelina and JUL 18 2005 Hazardous Materiais Safery Administration Mr. Kevin Anderson Ref. No. 04-0096 Manager Technical Services 3724 Hulen Street Chemical Lime Company Ft. Worth, Texas 76107 Dear Mr. Anderson: responds to your letter requesting assistance in classifying a chemical mixture for transportation by aircraft under the Hazardous Materials Regulations (HMR; 49 CFR Parts magnesium oxide meets the definition of a corrosive solid under 171-180). Specifically, you ask whether a mixture of calcium- the HMR and, if so, what would be the most appropriate shipping description for the material. I apologize for the delay in responding and any inconvenience it may have caused. Under § 173.22 of the HMR, it is a shipper's responsibility to properly classify a hazardous material. This Office does not Further, we do not have the capability to determine the corrosivity of an unlisted material, such as a mixture, without the results of tests conducted on the material as specified in SS 173.136 and 173.137. If you are not able to perform corrosivity testing on your material, we such recommend that you contact a laboratory capable of performing testing. The American Society for Testing and Materials (ASTM) maintains an internet website that offers a directory of website can be found at: laboratories that can satisfy this requirement. The ASTM www.astm.org. I trust this satisfies your inquiry. Please contact us if we can be of further assistance. Sincerely, Thall. z. Mitchel Hattie L. Mitchell Chief, Regulatory Review and Reinvention Office of Hazardous Materials Standards 172.10/ 040096 173.22#

Page 2stevens $173.22 3 |72.101 INFOCNTR Classifcation From: Sent: Kevin.Anderson@Chemicallime.com 04-0096 To: Wednesday, April 14, 2004 5:36 PM Cc: INFOCNTR Linda. Cannon@Chemicallime.com; Kevin.Ingram@Chemicallime.com; Subject: Fred.Huege@Chemicallime.com; Mark.Johnson@Chemicallime.com Air shipment of Ca-Mgo To whom it may concern, like an "informal response" as well. as "Formal interpretation" for the following Calcium-Magnesium Oxide, aka dolomitic quicklime by air. This product is produced by the concern. What is the proper way to ship (labelling, Proper Shipping Name to use, calcination of Dolomite represents more than 50% of the product. This material: (CaO-MgO) is not listed as a (CaCO3-MgCO3), to a resulting form Cao-Mgo. In the final form Cao gentleman named Kurt. He suggested we use the following description: regulated material in the 49 CFR. I called the RSPA 1-800, number today and spoke with a Proper Shipping Name- Calcium Oxide, Mixture a misrepresentation or mislabeling of our product Would this be (Corrosive) Packing Group- III I'm not sure who this will be directed to, but I hope it will find it's way to Edward Mazzullo. Manager, Technical Services Kevin Anderson 3724 Hulen St. Chemical Lime Company Ft. Worth, Texas 76107 800-365-6724 817-806-1623 Fax: 817-806-1633 Email: Kevin. Anderson@chemicallime.com#