The Fertilizer Institute — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Washington, D.C. 20590 400 Seventh Street, S.W. Pipeline and Administration Hazardous Materials Safety AUG 3 2005 Ms. Pam Guffain Reference: 05-0165 Director, Government Affairs The Fertilizer Institute 820 First Street, NE Suite 430 Washington, DC 20002 Dear Ms. Guffain: This is in response to your letter regarding the appropriate shipping description for various fertilizer blends under the Hazardous Materials Regulations (HMR; 49 CFR 171-180). The first blend consists of 50% ammonium nitrate, 25% potash, and 25% ammonium sulfate. The second fertilizer blend consists of 34% ammonium nitrate, 33% potash, 33% ammonium sulfate. The third is a blend of 75% ammonium nitrate, 12.5% potash and 12.5% ammonium Section 173.22 specifies that it is the shipper's responsibility to properly class and describe a material in accordance with the HMR. This office does not perform that function. Special provision 132, assigned to the entry "Ammonium nitrate based fertilizer, 9, UN 2071" applies to ammonium nitrate based fertilizers that (1) contain not more than 70% ammonium nitrate and not more than 0.4% total combustible, organic material calculated as carbon or (2) contain not more than 45% ammonium nitrate and unrestricted combustible material. Based on the criteria in Special provision 132 and the information you provided, it is our opinion that the first and second fertilizer blends specified should be described as "Ammonium nitrate based fertilizer, 9, UN 2071." Provided that the third fertilizer blend does not exhibit explosive properties of Class 1 when tested in accordance with Test Series 1 and 2 of Class 1 in the UN Manual of Tests and Criteria (see Special provision 52), this blend should be described as "Ammonium nitrate based fertilizer, 5.1, UN 2067." I hope this information is helpful. Sincerely, Thathe z. Mithe l Hattie L. Mitchell, Chief Office of Hazardous Materials Standards Regulatory Review and Reinvention 172.101 050165 173.22#

Page 2The Fertilizer Institute Corbin $172.101 Nourish, Replenish, Grow Pam Guffain Government Relations Director $173.22 Classification July 7, 2005 05-0165 Edward Mazzullo Director, Hazardous Materials Standards Pipeline and Hazardous Materials Safety Administration 400 Seventh Street, S.W. Washington, D. C. 20590 Dear Ed: We are looking for an official interpretation regarding the appropriation classification of several different mixes of ammonium nitrate. If you could review the mixers below and advise if they fall into the 5.1 classification or Class 9 classification: 50% ammonium nitrate, 25% potash, 25% ammonium sulfate 34% ammonium nitrate, 33% potash, 33% ammonium sulfate 75% ammonium nitrate, 12.5% potash, 12.5% ammonium sulfate Thank you very much and I look forward to hearing from you as soon as possible. Sincerely, Pamela D. Guffain 820 First Sten. NE Suite 430 Union (enter Plaza 202.962.0490 Washington, DC: 20002 www.tf.org 202 %62.0577 tax#