{"operation":"document","citation":"06-0244","title":"Fisher Scientific International, Inc. — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2006-12-07","effective_on":null,"summary":"06-0244 response to Fisher Scientific International, Inc. concerning 172.101.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-06-0244.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-06-0244.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-06-0244","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2006/060244.pdf","body":"<<>>\n\nof Transportation\nU.S. Department\nWashington, D.C. 20590\n400 Seventh Street, S.W.\nPipeline and\nAdministration\nHazardous Materials Safety\nDEL\n906\nMr. Gene Sanders\nDangerous Goods\nRef. No.\n06-0244\nFisher Scientific\nTransportation Specialist\n2000 Park Lane\nInternational, Inc.\nPittsburgh, PA\n15275\nDear Mr. Sanders:\nThis\nthe classification of Hollande's Solution under the\nresponds to your letter requesting clarification on\n180).\nHazardous Materials Regulations (HMR; 49 CFR Parts 171-\nproperly classified\nSpecifically, you ask for confirmation that you have\nacid, 1.2% methyl alcohol, 1.0-1.5% acetic acid,\na solution consisting of ‹ 2.38% picric\n> 90% water.\nformaldehyde, 2.0-2.5% copper diacetate monohydrate, and\nBased on PH value (3.48) and the minimal\nintend to describe it as \"UN3265, Corrosive liquid, acidic,\namount of picric acid in Hollande's Solution (< 2.38%) you\norganic, n.o.s. (Formaldehyde, Picric acid), 8, III.\" In\npreviously issued interpretations that would appear to\naddition, you enclosed with your request copies of two\nsupport your decision.\nAlthough the entry in the\n§ 172.101 Hazardous Materials\nnot specify a lower limit for the concentration of picric\nTable (HMT) for Picric acid (Trinitrophenol, wetted) does\nHollande's Solution should not be described as a\nacid in solution, we agree with your conclusion that\ndesensitized explosive of Hazard Class 3 or Division 1.1.\n172.101\n060244\n\n<<>>\n\nTherefore, we agree with your decision to describe\nHollande's\norganic, n.o.s. (Formaldehyde, Picric acid), 8, III.\"\nSolution as \"UN3265, Corrosive liquid, acidic,\nwe can be of further assistance.\nI trust this satisfies your inquiry. Please contact us if\nSincerely,\nHattie L. Mitchell\nOffice of Hazardous Materials Standards\nChief, Regulatory Review and Reinvention\n\n<<>>\n\nstevens\nPage 1 or z\n3/72.101\nClassification Shipping Name\nDrakeford, Carolyn \n06 - 0244\nFrom:\nGorsky, Susan \nSent:\nThursday, October 26, 2006 3:57 PM\nTo:\nDrakeford, Carolyn \nSubject:\nFW: Formal Interpretation requested\nAttachments: InterpLetter 2000 low percent picric.pdf; InterpLetter 2004 Bouins.pdf; Hollande's solution\nMSDS.pdf\nFor the interp data base. Thanks.\nSent: Thursday, October 26, 2006 3:12 PM\nFrom: Sanders, Gene [mailto: gene.sanders@fishersci.com]\nCc: Mayfield, John; Ke, Charles ; Ke, Charles \nTo: Gorsky, Susan \nSubject: Formal Interpretation requested\nMs. Gorsky,\nknown as Hollande's Solution, MSDS attached.\nFisher Scientific is requesting a formal interpretation regarding the transport classification of a product\nmaterial for transport. However, the 49CFR 172.101 Hazardous Materials Table also lists 90%, Trinitrophenol with\nHollande's Solution contains Trinitrophenol (Picric Acid), which when pure (dry) is regulaled as a Class 1\n10% water as being adequately desensitized, UN3364. 90% wetted with 10% is a 0.11-fold dilution. In\nwords, Hollande's Solution is 340 times more dilute than the minimum allowed\nHollande's Solution there is 2.38% Trinitrophenol and at least 90% water, which is a 37.81-fold dilution. In other\nMSDS, are expected to sensitize Trinitrophenol, nor to adversely affect the desensitization of Trinitrophenol by\nNone of the other ingredients in Hollande's Solution, all at concentrations less than 3.2%, and listed in the\nSo, we believe that this product is more than adequately desensitized.\nremains desensitized when precipitated but still wetted.\nmaterial, and while Nitroglycerin can be explosive when precipitated from an alcohol solution, Trinitrophenol\nworkers that it includes a desensitized explosive.\nSo, we believe that this product does not present a high enough risk to warrant informing transportation\nproduct is corrosive. There are three components of Hollande's Solution that when present in higher\nAlthough the pH of Hollande's Solution is 3.48, it is not always acidity alone that determines whether a\nconcentrations can each be corrosive on their own. Although none of these three components are believed to\nthe three, we do reasonably suspect that together they make the product a Class 8 material at the Packing Group\nmake Hollande's Solution corrosive by themselves, and we have not specifically tested for the cumulative effect of\n10/26/2006\n\n<<>>\n\nPage 2 of 2\ntollande's Solution, we do not believe Hollande's Solution is a 6.1 material, nor do we believe it to be a Class 3\nased upon the properties of the pure components, and the concentrations at which they are present ir\nmaterial. It is definitely not a 4.2 nor 4.3 material.\nUN3265, Corrosive liquid, acidic, organic, n.o.s. (Formaldehyde, Picric Acid), 8, III\nTherefore, we believe that the most appropriate transport classification for Hollande's Solution to be\nassification for Hollande's Solution. As always, we appreciate your assistance in keeping Fisher Scientific ar\ngain, Fisher Scientific is requesting a formal interpretation regarding the acceptability of this as a transpo\nour affiliated companies safely in compliance. Thank you.\nCheers,\nGene Sanders, DGSA\nDangerous Goods Transportation Specialist\n2000 Park Lane\nFisher Scientific International, Inc.\nPittsburgh, Pa. 15275 USA\n412/490-8934, cell 412/498-2458, fax 412/490-8930\nGene.Sanders @ Fishersci.com\n-;==;\nMSDS.pdf>>\n<> <> <