Thermo Fisher Scientific — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration OCT 2 1 2009 1200 New Jersey Ave, SE Washington, D.C. 20590 Mr. Gene Sanders, DGSA Senior Dangerous Goods Transportation Specialist Thermo Fisher Scientific, Customer channel Group 2000 Park Lane Pittsburg, Pennsylvania 15275 Ref. No. 09-0037 Dear Mr. Sanders: This responds to your e-mail regarding the classification of hydrogen gas at low pressure under the Hazardous Materials Regulations (HMR; 49 CFR Parts 17 1 - 180). Specifically, you ask whether the HMR apply to the transportation of a small quantity of hydrogen inside a glass tube or sphere if the hydrogen is shipped at a reduced pressure, rather than compressed. According to the information provided with your email, the hydrogen gas is shipped within a glass tube with a total capacity of 1.7 ml. The gas is shipped at a pressure lower than atmospheric pressure (75 tom). In the event that the glass tube or sphere were to break, the amount of hydrogen released (0.17 ml) would be insufficient to ignite (i.e., in a 1 -inch diameter tube or sphere, the concentration of the hydrogen would be below the 4% LEL). It is the opinion of this office that when packaged as described in your e-mail, the hydrogen is not shipped in a quantity and form that poses an unreasonable risk to health and safety or property and, therefore, is not subject to regulation under the HMR. I hope t h s satisfies your inquiry. If we can be of further assistance, please contact us. Sincerely, Charles E. Betts Standards Development of Hazardous Materials Standards#

Page 2Spectrum tubes with Hydrogen Page 1 of 1 Drakeford, Carolyn <PHMSA> w."-..-.-e-* .""",*-- "--- .."-*---- "- e m - -. From: Gorsky, Susan <PHMSA> Sent: Wednesday, February 18,2009 7:20 AIM To: Drakeford, Carolyn <PHMSA> Subject: FW: Spectrum tubes with Hydrogen From: Sanders, Gene [mailto:gene.sanders@thermofisher.com] Sent: Tuesday, February 17, 2009 4:41 PM To: Gorsky, Susan <PHMSA> Cc: Mayfield, John Subject: Spectrum tubes with Hydrogen Dear Ms. Gorsky, Thermo Fisher has a product that includes 1.7 mL of hydrogen gas at low pressure, 75 Torr, approximately 1110 of an atmosphere, inside a glass tube. In the event that the glass tube were to be broken, the hydrogen would return to atmospheric pressure, and its volume would become 0.17 mL, approximately one half of 1% of an ounce. As the hydrogen diffuses into air in a sphere 1 inch across, it becomes too dilute to ignite, (i.e., in a 1 inch diameter sphere, the concentration of that much hydrogen would be below the 4% LEL). Because of the extremely small quantity of hydrogen in this article, and because it is shipped at a reduced pressure rather than compressed, we do not believe that it poses an unreasonable risk to health, safety, or property when shipped in commerce, and therefore is not a hazardous material for transport. Does PHMSA disagree with this classification? Thank you. Cheers, Gene Sanders, DGSA Senior Dangerous Goods Transportation Specialist Thermo Fisher Scientific, Customer Channels Group 2000 Park Lane Pittsburgh, Pa. 15275 USA Gene.Sanders@ThermoFisher.com 41 21490-8934, cell 4121498-2458, fax 41 21490-8930 www.thermofisher.com The world leader in serving science WORLDWIDE CONFIDENTIALITY NOTE (Optional): Dissemination, distribution or copying of this e-mail or the information herein by anyone other than the intended recipient, or an employee or agent of a system responsible for delivering the message to the intended recipient, is prohibited. If you are not the intended recipient, please inform the sender and delete all copies. ' .'Cr..#