Fisher Scientific International, Inc. — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department Washington, D.C. 20590 400 Seventh Street, S.W. Pipeline and Administration Hazardous Materials Safety DEL 906 Mr. Gene Sanders Dangerous Goods Ref. No. 06-0244 Fisher Scientific Transportation Specialist 2000 Park Lane International, Inc. Pittsburgh, PA 15275 Dear Mr. Sanders: This the classification of Hollande's Solution under the responds to your letter requesting clarification on 180). Hazardous Materials Regulations (HMR; 49 CFR Parts 171- properly classified Specifically, you ask for confirmation that you have acid, 1.2% methyl alcohol, 1.0-1.5% acetic acid, a solution consisting of ‹ 2.38% picric > 90% water. formaldehyde, 2.0-2.5% copper diacetate monohydrate, and Based on PH value (3.48) and the minimal intend to describe it as "UN3265, Corrosive liquid, acidic, amount of picric acid in Hollande's Solution (< 2.38%) you organic, n.o.s. (Formaldehyde, Picric acid), 8, III." In previously issued interpretations that would appear to addition, you enclosed with your request copies of two support your decision. Although the entry in the § 172.101 Hazardous Materials not specify a lower limit for the concentration of picric Table (HMT) for Picric acid (Trinitrophenol, wetted) does Hollande's Solution should not be described as a acid in solution, we agree with your conclusion that desensitized explosive of Hazard Class 3 or Division 1.1. 172.101 060244#

Page 2Therefore, we agree with your decision to describe Hollande's organic, n.o.s. (Formaldehyde, Picric acid), 8, III." Solution as "UN3265, Corrosive liquid, acidic, we can be of further assistance. I trust this satisfies your inquiry. Please contact us if Sincerely, Hattie L. Mitchell Office of Hazardous Materials Standards Chief, Regulatory Review and Reinvention#

Page 3stevens Page 1 or z 3/72.101 Classification Shipping Name Drakeford, Carolyn <PHMSA> 06 - 0244 From: Gorsky, Susan <PHMSA> Sent: Thursday, October 26, 2006 3:57 PM To: Drakeford, Carolyn <PHMSA> Subject: FW: Formal Interpretation requested Attachments: InterpLetter 2000 low percent picric.pdf; InterpLetter 2004 Bouins.pdf; Hollande's solution MSDS.pdf For the interp data base. Thanks. Sent: Thursday, October 26, 2006 3:12 PM From: Sanders, Gene [mailto: gene.sanders@fishersci.com] Cc: Mayfield, John; Ke, Charles <PHMSA>; Ke, Charles <PHMSA> To: Gorsky, Susan <PHMSA> Subject: Formal Interpretation requested Ms. Gorsky, known as Hollande's Solution, MSDS attached. Fisher Scientific is requesting a formal interpretation regarding the transport classification of a product material for transport. However, the 49CFR 172.101 Hazardous Materials Table also lists 90%, Trinitrophenol with Hollande's Solution contains Trinitrophenol (Picric Acid), which when pure (dry) is regulaled as a Class 1 10% water as being adequately desensitized, UN3364. 90% wetted with 10% is a 0.11-fold dilution. In words, Hollande's Solution is 340 times more dilute than the minimum allowed Hollande's Solution there is 2.38% Trinitrophenol and at least 90% water, which is a 37.81-fold dilution. In other MSDS, are expected to sensitize Trinitrophenol, nor to adversely affect the desensitization of Trinitrophenol by None of the other ingredients in Hollande's Solution, all at concentrations less than 3.2%, and listed in the So, we believe that this product is more than adequately desensitized. remains desensitized when precipitated but still wetted. material, and while Nitroglycerin can be explosive when precipitated from an alcohol solution, Trinitrophenol workers that it includes a desensitized explosive. So, we believe that this product does not present a high enough risk to warrant informing transportation product is corrosive. There are three components of Hollande's Solution that when present in higher Although the pH of Hollande's Solution is 3.48, it is not always acidity alone that determines whether a concentrations can each be corrosive on their own. Although none of these three components are believed to the three, we do reasonably suspect that together they make the product a Class 8 material at the Packing Group make Hollande's Solution corrosive by themselves, and we have not specifically tested for the cumulative effect of 10/26/2006#

Page 4Page 2 of 2 tollande's Solution, we do not believe Hollande's Solution is a 6.1 material, nor do we believe it to be a Class 3 ased upon the properties of the pure components, and the concentrations at which they are present ir material. It is definitely not a 4.2 nor 4.3 material. UN3265, Corrosive liquid, acidic, organic, n.o.s. (Formaldehyde, Picric Acid), 8, III Therefore, we believe that the most appropriate transport classification for Hollande's Solution to be assification for Hollande's Solution. As always, we appreciate your assistance in keeping Fisher Scientific ar gain, Fisher Scientific is requesting a formal interpretation regarding the acceptability of this as a transpo our affiliated companies safely in compliance. Thank you. Cheers, Gene Sanders, DGSA Dangerous Goods Transportation Specialist 2000 Park Lane Fisher Scientific International, Inc. Pittsburgh, Pa. 15275 USA 412/490-8934, cell 412/498-2458, fax 412/490-8930 Gene.Sanders @ Fishersci.com -;==; MSDS.pdf>> <<InterpLetter 2000 low percent picric.pdf>> <<InterpLetter 2004 Bouins.pdf>> <<Hollande's solution 10/26/2006#