{"operation":"document","citation":"04-0285","title":"The Field Museum — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2005-04-26","effective_on":null,"summary":"04-0285 response to The Field Museum concerning 172.101, 173.132.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-04-0285.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-04-0285.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-04-0285","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2004/040285.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\n400 Seventh Street, S.W.\nof Transportation\nWashington, D.C. 20590\nPipeline and\nHazardous Materials Safety\nAPR 26 2005\nAdministration\nMs. Jolynn Parchen\nRef. No. 04-0285\nSafety and Benefits Manager\nHuman Resources\nThe Field Museum\n1400 S. Lake: Sore Drive\nChicago, Illinois 70605-2496\nDear Ms. Parchen:\nThis responds to your letter dated December 17, 2004 regarding the Hazardous Materials\nRegulations (HMR; 49 CFR parts 171-180 as they apply to the shipment of museum artifacts\npreserved wirh arsenic dust. Specifically, you ask if shipments of artifacts treated with arsenical\ndust are not subject to the HMR. You provided information, as follows:\nFrom the 1890s into the1940s, natural history museums, like the Field Museum,\nused arsenical dust as a pesticide to help preserve certain artifacts in their\ncollections. Generally, these artifacts are made of organic materials such as hides,\nfeathers, fur or wood. The residue of this arsenical dust remains on the surface of\ntreated artifacts.\nThe Merckoquant® Arsenic Test is used to determine whether or not the artifact\nhas been contaminated with arsenic. Using the Merckoquant® Arsenic Test, the\nmuseum determined that the most contaminated artifacts tested at less than 0.003\ngrams per liter arsenical dust from 1 cm' area swab. This is equivalent of 0.014\ngrams per square foot of arsenical dust on the entire artifact surface. For example,\nthe largest contaminated object tested to date is a New Guinea mask of maximum\ndimer.sions 20' × 4'x4', having a surface area of 320 square feet. A total of 4.9\ngrams arsenical dust would be present on the surface area of the mask if the whole\nsurface were equally contaminated.\nThe Field Museum receives numerous requests each year from other institutions\nto loan artifacts to them for research and public exhibition. For preservation\nreasors, artifacts that move in transportation are packed in multiple layers of\nimpact, shock, and vibration absorbing materials. The custom-made crates are\nmade of 5/8\" plywood and 1\" by 4\" wood battens that are lined with at least 2'\nthick planks of medium to high density closed cell polyester foam. Each artifact is\nin its own custom-made internal compartment that is made with lower density\npolyester foam and lined with Tyvek™ polyethylene sheet.\n172.101\n040285\n173.132\n\n<<<PAGE 2>>>\n\nUnder the HMR, tests to determine if a material meets the definition for a Division 6.1\n(poisonous) material are found at § 173.132, which specifies oral, dermal or inhalation toxicity\ncriteria. If a material does not meet the criteria for a Division 6.1 (poisonous) material or any\nother hazard class, it is not subject to the requirements of the HMR.\nAlthough a residue of the arsenical dust remains on the surface of the artifacts, it is our opinion\nhazard that may be present during transportation. Therefore, shipments of artifacts with surface\nthat the packaging you utilize for shipment of the artifacts is sufficient to mitigate the minimal\nresidues of arsenical dust that are packaged as described in your letter are not subject to\nregulation under the HMR.\nI hope this satisfies your inquiry. If we can be of further assistance, please contact us.\nChief, Stancards Development\nOffice of Hazardous Materials Standards\n\n<<<PAGE 3>>>\n\nDEC-17-2004 15:52\nFROM:\nMuseum\nField\nlexploring\nthe\nearth\nand\nits\npeople\ntnarum\n3172.101\n3173.132\nAplicabilily\nDecember 17, 2004\n04-0285\nMr. Edward T. Mazzullo\nU.S. DOT/RSPA (DHM-10)\nDirector, Office of Hazardous Materials Standards\n400 7th Street S.W.\nWashington, D.C. 20590-0001\nRe: Letter of Interpretation\nDear Mr. Mazzullo,\nartifacts preserved with arsenic dust. We hope that by providing you with technical\nWe are writing to obtain a letter of interpretation concerning the shipment of museum\ninformation and the results of our arsenic testing, you could determine if we would need\nto meet the hazardous materials shipping requirements of HMR 49 CFR.\narsenical dust as a pesticide to help preserve certain artifacts in their collections.\nFrom the 1890s into the 1940s, natural history museums, like the Field Museum, used\nGenerally, these artifacts are made of organic materials such as hides, feathers, fur or\nwood. The residue of this arsenical dust remains on the surface of treated artifacts. We\nuse the Merckoquant® Arsenic Test to determine whether or not an artifact in our\ncollection has been contaminated with arsenic.\nUsing the Merckoquan® Arsenic Test, we were able to determine that the most\ncontaminated artifacts tested at less than 0.003 grams per liter arsenical dust from 1 cm?\narea swab. This is the equivalent of 0.014 grams per square foot of arsenical dust on the\nentire artifact surface. As an example, the largest contaminated object tested to date is a\nNew Guirea mask of maximum dimensions 20'x 4'x4', thus a surface area of 352 square\nfeet. This would be a total of 4.9 grams arsenical dust, if the whole surface were equally\ncontaminated.\nIn November 2001, we contracted with an environmental hazard consulting firm, The\nRaterman Group, to determine if our staff members were being exposed to elevated levels\nof arsenic dust while handling our collections. The Ratermar: Group performed personal\nir exposure tests on a group of our collections staff. During this sampling period\nxposure-monitoring pumps were placed on individual collection staff while thei\nperformed their routine work activities. This included cataloging and moving artifacts,\n1400 S. Lake Shore Drive\nChicago, Illinois 60605-2496\nTelephone 311.922.9410\nP'rinted on acrycled paper\n\n<<<PAGE 4>>>\n\nDEC-17-2004 15:52 FROM:\nTO: 912023663012\nF.3\nvacuuming shelves and taking inventory of the collections. These work activities were\norganized to represent an above average load of work for one day.\nThese monitoring tests determined that the seven-hour (seven hours represent a full\nMuseum. work day) time-weighted average exposures for these staff members were well\nworkday. Through this sampling, we know that staff handling or moving artifacts in our\nbelow OSHA's action level and the permissible exposure lirits allowed for staff during a\ncollections are not exposed to elevated levels of airborne arsenic dust.\nThe Field Museum receives numerous requests each year from other institutions to loan\nartifacts from our collection for the purposes of research and public exhibition. For\npreservation reasons, artifacts that travel are packed in multiple layers of impact, shock\nand vibration absorbing materials. These constitute custom made crates made of 5/8\"\nplywood and 1\" by 4\" wood battens that are lined with at least 2\" thick planks of medium\nto hima domi chased el oneser on over deraily po is nested in and incustom made\nTyvek™M polyethylene sheet. In short each artifact that is shipped by the Field Museum is\npacked in multiple layers of protective materials.\nrequirements of HMR 49 CFR 173.132(d), if we need to ship artifacts from our collection\nBased or our test results and current shipping procedures, are we subject to the\nthat have been treated with arsenic dust? If you need further information to make a\ndetermination, please feel free to contact me at (312) 665-7278.\nThank you very much for your time and I look forward to your response.\nJolynn Parchen\nHuman Resources\nSafety and Benefits Manager","truncated":false,"body_characters":7312}