# Samax Enterprises — Hazardous Materials Safety Interpretation

- **operation:** document
- **citation:** 06-0136
- **title:** Samax Enterprises — Hazardous Materials Safety Interpretation
- **source type:** guidance
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** guidance
- **official:** true
- **published on:** 2006-07-11
- **effective on:** Not available
- **summary:** 06-0136 response to Samax Enterprises concerning 172.419, 173.22.
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-interpretation-06-0136.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-interpretation-06-0136.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-interpretation-06-0136
- **source url:** https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2006/060136.pdf
**body:**

<<<PAGE 1>>>

U.S. Department
of Transportation
400 Seventh Street, S.W.
Washington, D.C. 20590
Pipeline and
Administration
Hazardous Materials Safety
JUL 11 2006
Mr. Perry J. Patton
Ref. No.: 06-0136
154 Eastwood Blvd.
Samax Enterprises
Centereach. NY 11720
Dear Mr. Patton:
requirements of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).
This is in response to your May 26, 2006 letter regarding the marking and labeling
You include a flammable liquid hazard label, an inhalation hazard label, and an
(MSDS) for the "Liquid No Wash" product. Specifically, you ask if the labels and
orientation arrow marking in your letter. You also provide a Material Safety Data Sheet
orientation markings included in your letter are required to be displayed on a 5-gallon
container of the product.
Under § 173.22, it is the shipper's responsibility to properly class and describe a
hazardous material. Marking and labeling requirements are based on the proper shipping
description of the hazardous material. The MSDS sheet for your product indicates the
PG II." For a material described as such, the "Flammable liquid" label specified in
proper shipping description for "Liquid No Wash" is "Paint related material, 3, UN1263,
§ 172.419 and included in your letter must be displayed on the outer surface of the
ackage. An inhalation hazard label may not be displayed on a package containin
Liquid No Wash" because the material does not meet the definition of a poiso
inhalation hazard. Orientation arrow markings must be displayed on two opposite
vertical sides of a combination package having inner packagings containing liquid
displayed on the surface of a single package (e.g., a 5-gallon container) or inne:
hazardous materials. Although not required by the HMR, orientation arrows may be
packaging.
I hope this information is helpful. If you have further questions, please do not hesitate to
contact this office.
Sincerely,
Chief, Standards Development
Office of Hazardous Materials Standards
172.419
173.22
060136

<<<PAGE 2>>>

:
Eichenlaub
§172.
• 400,419
§113.22.
SAMAX ENTERPRISES
labeling
06-0136
May 26, 2006
To: Edward Mazzullo
From: Perry J. Patton
Dear Sir:
We are requesting a review of the enclosed 5-gallon container labels.
label. Are we or are we not required to use both? Which label takes precedence over the other?
Our biggest concer is the inclusion on the container of the flammable liquid label and inhalation hazard
Any assistance you can provide will be greatly appreciated.
If you want to speak to us directly, please contact me at the following number. 631-580-2237.
Otherwise, I can be reached at the following:
Address:
154 Eastwood Bivd.
Centereach, NY 11720
Fax:
631-580-2239
E-mail:
oshacorp@optonline.net
Thank you.
Regards,

<<<PAGE 3>>>

FROM :
FAX NO. :
Jun. 16 2006 Ø1:16PM P2
MATERIAL SAFETY DATA SHEET
LIQUID NO WASH
Revised: January 2003
[ Cheniont Product and Company Identification
Product Name
Synonyms and Trade Names
Liquid No Wash
Chemical Pamily
Proprietary Mixture
Formula
Not Applicable
Organic Solvent Mixturc
Telephone (Fmergencies)*
Telephone (General Information)
1-800-545-7658
Samax Enterprises
1-800-424-9300
Company Address
*In case of an emcrgency involving spills, leaks, fire exposure, or accidents related to this produci call
29-75 Riverside Ave, Newark, N.J. 07104
CHEMTREC - 1-800-424-9300.
12. Composition / Information on Ingredients
INGREDIENT
Dichloromethano
CAS NUMBER
FOO2, Koop Away From
HAZARD CLASS
ACGIH TLV-TWA
D001, Flammable Liquid
50 ppm PFI**
100 ppm 1T.V
25 ppm PEL**
D001, Flammable Liquid
Acetone
67-64-1
D001, Flammable Liquid
Poison
1000 ppm PEL **
50 pm 1LV
** PEL = OSHA Permissible Exposure Limit
L3 Physical Data
Vapor Pressure @ 20°C.
Boiling Point
40°C
104°P
Vapor Density @) 1 Atmosphere
< 1 atm.
PH
Specific Gravity
NA
.98
Appearance
Percent Volatile by Volume
> 90
< 8.9
Odor
Clear to Slighty Cloudy Liguld
Physical State
Evaporation Rate (ether =i)
Solvent, Aromatic
Solubility
Liquid
Flash Point
> 40%
47°C
90°F

<<<PAGE 4>>>

FROM :
FAX NO. :
Jun. 16 2006 Ø1:16PM P3
24. Health Hizard Data.
2:2203
1202
• Potential effects of a single (Acuto Overexposure)
Eye:
May cause severe burns and possible irruversible eye damage if contact is made.
Skin:
May be irritating if confined un the skin by gloves or clothing. May be absorbed slowly
hrough the skin into the bloodstream and cause symploms listed below under inhalatior
Ingestion: May cause blindness and death. May cause headachc, nausea, vomiting, diarrhca, blood
in urine, dizziness and unconsciousioss.
Chronic:
CM is listed as a possible carcinogen by the ACGIH. Chronic over exposure to Toluer
system.
lay cause kidney and liver failure. Methanol causos toxic effect to the central nervol
ES. First Aid Measures
Note: Specialized First Aid and Medical Treatment are Required for all Exposures
Eyes:
minutes, occasionally lifting the upper and lower lids. Seek medical aid immediately.
Remove contact lenses (if applicable). Plush yos with plenty of water for at Icast 15
Skin:
removing any contaminated clothing. Do not try to neutralize with chemicals. Seel
lush effected area of skin with plunty of soap and water for at least 15 minutes while
medical aid immediately.
Ingestion:
Never give anything by mouth to an unconscious person. Sock medical
aid immediately. If conscious, give large amounts of wator to drink and induce vomiting.
Inhalation: Remove from exposure to fresh air immediately. Keep the victim quit, lying down and as
comfortable as possible. Seck immediately medical attention. If not breathing, give
artificial respiration at once. If breathing is difficult, give oxygen.
Notes to Physician: Treat symptomatically and supportively.
L6. Fire Fighting Measures
General Information: Product is highly fammable. Vapors may ignite under certain conditions when
bum on top of water. Cool exposed containers.
exposed to an ignition source. Product is only partially soluble in water and may float and
Extinguishing Media: Extinguish fire using an agent suitable for type of surrounding fire c.f. foam,
CO2, or dry chemical. Water may be used as a last resort.

<<<PAGE 5>>>

FROM :
FAX NO. :
Jun. 16 2306 Ø1:16PM P4
7-Accidóntil Release Mensures: "
22C
Spills/Leaks: Woar suitable Personal Protective Fiquipment (PPE). Vontilalc the area as wel! a
vermiculite, dry sand, earth, or similar material and place into a scaled container for proper
possible before entering. E'liminate/remove any source of ignition. Absorb liquid witt
Hundling: Always wear suitable PPE. Rubher or viny! gloves are recommended, do not wear leathe
or cloth. Wash thornughly after handling. Romove contaminated clothing and wash before re
sc. , and a duac vinitation. Keep container tighty closed, avold skin and eye
8, Exposire Controls, Personal Protection Eguipment
Engineering Controls: Use adequate general or local oxhaust ventilation to keep airborne
concentrations below the permissible exposure limit of 25 ppm.
Personal Protective Equipment:
Eyes:
Skln:
Wear appropriate protective clothing to provont skin exposure.
Clothing: Wear appropriate protective clothing to prevent skin exposure.
Respirators: Where required, use an appropriate NIOSH, OSHA, or MSHA respirator as applicable.
Some exposures may require a SCBA. Follow the OSHA respirator regulations found in 29
CFR 1910.134 or European Standard EN 149 for approved respirator when necessary.
(Stability and Reactivity.
Chomical Stahility: Stable under normal tempcrature and pressures.
Conditions 1o Avold: Keep away from food products, acids, strong oxidizers, alkali metals, heat and
spark or flame producing items.
Huzardous Decomposition Products: Nol Applicable.
Hazardous Polymerization: Will not occur.

<<<PAGE 6>>>

FROM :
FAX NO. :
Jun. 16 2006 Ø1:17PM P5
Eio. Regulatory Information
CERLA RQ:
73-09-2-1.000lbs
108-88-3=1,000lbs
7-56-1=5,000 1b
7-64-1=5,0001bs
RCRA D Sertes:
RCRA F Series:
CAS# 108-88-3 - D001, CAS# 67-64-1 - D001, and CAS# 67-56-1 - D00
CRA U Sorles
RCRA l' Series:
:AS# 75-09-2 - F002
one Liste
one Listi
US D.O.T. Hazard Class: 3
US D.O.T. Shipping Name: Paint Related Material
US D.O.T. Identification Number: UN 1263 Pkg I1
• Health:
HMIS & NFPA Information:
• Flammability:
3
• Reactivity:
• Corrosivity:
2
ISCA:
• Health and safety list: None of the chemicals in this product are listed.
None of the chemicals in this product are listed.
• Chemical test rules: None of the chemicals in this product are under a chemical test rule.
SARA: REPORTABLE QUANTITY (RQ):
• CAS# 108-88-3 RQ amount: 1000/454
• CAS# 75-09-2 RQ amount: 1000/454
• CAS# 67-64-1 RO amount: 5000/2270
• None of the chomicals in this product have a TPQ.
CAS# 67-56-1 RQ amount: 5000/2270
CLEAN AIR AC'I:
75-09-2; clean air rulo -yes
• 67-56-1; clcan air rule-yes
108-88-3; clean air rule-yes
• This material does not contain any class 2-ozone depletors
This material does not contain any class 1-ozone deplotors
[11. Toxicological Information
75-09-2 and 67-56-1 are considered toxic by OSHA
LC - 200-300 mg/kg orally in rats
12224
CAS# 67-64-1
LCsn - 7.53 g/kg orally in rats
L.Cso.. 10.7 ml/kg orally in rats
Epidemiology:
R, IARC-2E
No information available.

<<<PAGE 7>>>

FROM
:
FAX NO. :
Jun. 16 2006Ø1:17PM PS
Teratopenicity:
productive orecis
No information available.
Neurotoxicity:
o information available
Muta penicity:
No information available.
No information available.
112 Additional Information
vailable to SAMAX Enterprises Inc. However, SAMAX Inc. makes no warranty of merchantabilit
The information above is beloved to be accurate and represents the best information currentl
say to war re, in to or use users reside on sue eir own in aigions to determine.
the suitability of the information for their particular purpose. In no way shall SAMAX Inc. be liable
incidental, consequential or exemplary damages, howsoover arising even if SAMAX Inc. bas been
for any claims, losses, or damages of any third party or for lost protits or any special, indirect,
advisod of the possibility of such damages.

<<<PAGE 8>>>

6-HML-R
FLAMMABLE LIQUID
eenah, Wisconsin 59957-0368: 1800) 327,6868:
ublished by: J.J. KELLER & ASSOCIATES INC
3
INHALATION
198-HML-R
HAZARD
Published by is me, i SA 0012 C

<<<PAGE 9>>>

31-HML-F
Neenah, WI • USA • (800) 327-6868
Published by: J.J. KELLER & ASSOCIATES, INC.

<<<PAGE 10>>>

surfaces.
safety glasses.
not transfer
Rock Miracle Liquid No Wash
Remover is ideal for ornamental
afterwash is necessary. Liquid
No Wash quickly softens paint,
enamel, latex, lacquer, varnish,
shellac and urethanes from
wood, metal, plaster, and
masonry without injury to these
surfaces. Do not allow to drip
on linoleum, asphalt, rubber
tile and synthetics. It may also
soften fiberglass and plastic.
DIRECTIONS: Wear protective
Shake can well. Open slowly
with container opening away
from your face and close after
contents of can to unlabeled
bottles or other containers.
Always test a small area for
removal time. Apply a heavy
coat using a polyesther brush
or for continuous flow, pour
from a glass or metal cup to a
confined area of no more than 3
square feet at a time. Allow
Liquid No Wash to penetrate for
at least 15 minutes. Scrape off
softened finish with a scraper
or steel wool pad till area is
completely cleaned. Use a
toothbrush or pointed object
for carved areas. Thoroughly
wipe area with absorbant cloth
to remove residue before
proceeding to next area. No
further surface preparation is
Made in USA
Samax Enterprises, Inc.
Newark, NJ 07104-4237
use. Do
necessary.
1936
POISON!
ROCK-MIRACLE
FLAMMABLE LIQUID AND VAPOR.
MAY BE FATAL OR CAUSE BLINDNESS IF SWALLOWED.
VAPOR HARMFUL. MAY CAUSE FLASH FIRE.
N CE
No Wash-
REMOVER
No afterwash necessary!
DANGER!
Removes
and varnish.
paint,
finishes

<<<PAGE 11>>>

Store in cool place. Do not reuse container.
depends on level and duration of exposure.
KEEP OUT OF THE REACH OF CHILDREN.
unused contents in accordance with local, state and federal regulations.
build-up of vapors by opening all windows and doors to achieve good ventilation.
surfaces may produce toxic gases. Keep away from heat and flame. Do not smoke.
material and remove with inert absorbent. Dispose of contaminated absorbent, container and
Swallowing: If swallowed, get medical attention immediately. Spills: If spilled, contain spilled
inhaled, remove to fresh air. If not breathing, give artificial respiration: If breathing is difficult,
and shoes. Wash clothing before reuse. Thoroughly clean contaminated shoes. Inhalation: If
water for at least 15 minutes. Get medical attention immediately. Remove contaminated clothes
FIRST AID: Eyes and skin: In case of contact, immediately flush eyes or skin with plenty of
electric motors and other sources of ignition during use and until all vapors are gone. Prevent
cause flash fire. Do not smoke. Extinguish all flames and pilot lights and turn off stoves, heaters,
VAPORS MAY IGNITE EXPLOSIVELY. Keep away from heat, sparks and flame. Vapors may
papers and waste promptly. Allow solvent to evaporate, then dispose of in metal containers.
protection against vapors. Open containers carefully and close after each use. Clean up rags,
additional protection. Obtain professional advice before using. A dust mask does not provide
Do not use in basement or other unventilated area. If properly used, a respirator may offer
use it indoors, prevent buildup of vapors by opening all windows and doors to achieve good
USE ONLY WITH ADEQUATE VENTILATION. Use this product outdoors if possible. If you must
concentrating and inhaling the contents may be harmful or fatal. Contact with flame or hot
with permanent brain and nervous system damage. Intentional misuse by deliberately
Notice: Reports have associated repeated and prolonged occupational overexposure to solvents
with eyes, skin and clothing. Causes eye, nose, throat and skin irritation. Risk to your health
blood's oxygen-carrying capacity. May be fatal or cause blindness if swallowed. Avoid contact
May affect the brain or nervous system causing dizziness, headache for nausea. Reduces the
pulmonary disorders and women who are pregnant should consult their physician before using
blood's oxygen carrying capacity. People having or suspected of having heart trouble or any
CANCER IN CERTAIN LABORATORY ANIMALS. CANNOT BE MADE NON-POISONOUS. Reduces
VAPOR HARMFUL. CONTAINS METHYLENE CHLORIDE WHICH HAS BEEN SHOWN TO CAUSE
CANNOT BE MADE NON-POISONOUS!
HEAT, SPARKS AND OPEN FLAME!
DANGER! FLAMMABLE MIXTURE! KEEP AWAY FROM
TOLUENE CAS# 108-88-3 PETROLEUM WAX
ACETONE CAS# 67-64-1 METHYL ALCOHOL CAS# 67-51-1
Ingredients: Contains METHYLENE CHLORIDE CAS# 75-09-02
implied
material safety data sheet.
095555051607
297.5 GRAMS PER LITER
MAX VOC
further information refer to the
regardless of legal theory. For
damage to person or property
will not be responsible for any
The manufacturer and distributor
damages to persons or properties.
proper use of this product and for
full responsibility for the safe and
The purchaser and users assume
defective product will be replaced.
express or implied warranties. Any
merchantability and any or all
and distributor disclaim the
used or misused, the manufacturer
warranty
under which this product may be
Because of the wide conditions
efficient when used properly.
and Finish Remover is safe and
Rock Miracle Liquid No Wash Paint
or
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