Cytec Industries Stamford Hazards Lab — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Ave. S.E. Washington, D.C. 20590 Mr. Mark Ryan Cytec Industries Stamford Hazards Lab 1937 W Main St Stamford, CT 06902-45 16 Ref. No. 09-0144 Dear Mr. Ryan: This responds to your June 19, 2009 letter requesting clarification on whether the attached ARC test method may be used to determine a material's self-accelerated decomposition temperature (SADT) under $173.21.(f) of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if a test method, other than those listed in Part 11, Section 28, test series H of the UN Manual of Tests and Criteria, may be used to meet the requirements of 5 173.21(f) of the HMR. The answer is yes. Section 173.21(f) specifies the SADT may be determined by any of the test methods described in Part 11, of the UN Manual of Tests and Criteria. These UN provisions, in 28.2.2, also provide that test methods, other than those listed, are authorized provided the alternative method gives the correct SADT of the nlaterial as packaged for transport. I trust this satisfies your inquiry. Please contact us if we can be of further assistance Sincer y, - dattie L. Mitchell Chief, Regulatory Review and Reinvention Office of Hazardous Materials Standards#

Page 2Page 1 of 4 Drakeford, Carolyn (PHMSA) From: Gorsky, Susan (PHMSA) Sent: Friday, June 19, 2009 7:29 AM To: Drakeford, Carolyn (PHMSA) Subject: FW: Alternative method for SADT test Attachments: FAI-2009-139 - Cytec Alternative SADT Method.pdf From: Ryan, Mark [mailto:Mark.Ryan@cytec.com] Sent: Thursday, ~ u n e 18, 2009 1:58 PM. To: Gorsky, Susan (PHMSA) Cc: Ke, Charles (PHMSA); Brown, James Subjed: RE: Alternative method for SADT test Dear Ms. Gorsky. We developed tlie attached alternative SADT rnethod along with a consultant, Fa11sk.e - Associates, and obtained approval for tising the rrietliod l'rom the DO'S. If it is not too much trouble. \ye would like to have a brief official letter li)r our files referencing the report that indicates the method has been accepted by tlie DOT. Please let me know if 1 can providc any fi~rther information. From: charles.ke@dot.gov [maiIto:charles.ke@dot.gov] Sent: Thursday, June 18, 2009 1:51 PM To: Ryan, Mark Cc: charles.ke@dot.gov; susan.gorsky@dot.gov Subject: RE: Alternative method for SADT test If you need an official interpretation letter, you need to send in a request together with your document to our Standards Office attn: Ms. Susan Gorsky. Charles Ke From: Ryan, Mark [mailto:Mark.Ryan@cytec.com] Sent: Thursday, June 18, 2009 1:46 PM To: Ke, Charles (PHMSA) Subjed: RE: Alternative method for SADT test Deal. Mr. Ke. If it not too much trouble, we would like to have a brief official letier for our i71es referencing the report (FA1!09- 139, AII Alternative Method for Determination (:)ftlie Self-Accelerating Decomposition Temperature) that indicates tlie rncthod has been accepted by the DO'I'. Thanks for the good news, Mark#