Detector Electronics Corporation — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Ave, SE Washington, D.C. 20590 MAR 1 2010 Mr. Jon Varner Director of Engineering Detector Electronics Corporation 6901 West 1l0lh Street Minneapolis, Minnesota 55438 Ref. No. 10-0012 Dear Mr. Vamer: This responds to your email dated January 12,2010 requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Your company manufactures a gas detection device designed to detect hydrogen sulfide (H2S). The calibration method for the H2S gas detection device requires the use ofglass ampoules containing H2S. Specifically, you ask PHMSA to confirm that based on the LCso value, the method of packing, and shipment quantities, the H2S ampoules are transported in a form and quantity that does not pose an unreasonable risk to health and safety or property, and therefore are not subject to the HMR. You provide the following supplemental information: Each ampoule has a volume of 7 ml and is filled with H2S, which based on your calculations is equivalent to a concentration of 0.49%. You have determined through calculations that the LCsoofthe H2S mixture contained in each glass ampoule is 145,510 ml/m3 • The ampoules are packed in blocks of foam, 6 ampoules per block. Two foam blocks are packed per corrugated outer box. These boxes are then overpacked in a box with 300 Ibs. burst strength with additional packing material, andlor other items, Shipments typically include 100 ampoules and are not anticipated to exceed 1,000 ampoules, A Division 2.3 (gas poisonous by inhalation) material is defined as a gas that is known to be so toxic to humans as to pose a hazard to health during transportation; or, in the absence of data on human toxicity, is presumed to be toxic to humans because when tested in a laboratory it has an LCso of 5,000 mllm3 , Based upon the calculated LCso, the material you describe in your letter#

Page 2does not meet the definition of a Division 2.3 material. Therefore, provided the material does not meet the definition of any other hazard class, it is not subject to the requirements of the HMR. I hope this answers your inquiry. If you need further assistance, please contact this office at 202366-8553. Sincerely, ~~i~ ~ Charles E. Betts . f, Standards Development Office ofHazardous Materials Standards#

Page 3~ DET.TRONICS® 6901 West 11 Oth Street Detector Electronics Corporation Minneapolis, MN 55438 USA Tel 952.941.5665 Fax 952.829.8750 A UTe Fire & Security Company www.det-tronics.com f..; c £1eVl laA-b January 12, 2010 S 113. 13 Z Mr. Charles E. Betts ~ 172. I 0 1 fJ , 73 . " S- Chief, Standards Development Cta~5if, c.a..:h 0(\ Office of Hazardous Materials Standards 10· 00/0 Pipeline and Hazardous Materials Safety Administration Attn: PHH-10 U.S. Department of Transportation East Building 1200 New Jersey Avenue, SE Washington, DC 20590-0001 Re: Request for Advisory Opinion on the Hazardous Classification of H2S Ampoules Dear Mr. Betts: Detector Electronics Corporation (DEC) manufactures safety solutions including flame detection, gas detection and safety systems for use in hazardous industrial applications. As part of our industrial gas detection product line, we manufacture a line of toxic gas detectors which require routine calibration to ensure detection accuracy. The method for calibration of our hydrogen sulfide (H2S) gas detectors involves the use of glass ampoules containing a small quantity of H2S., and the purpose of this letter is to confirm our view that transportation of the ampoules is not subject to DOT's Hazardous Materials Regulations ("HMR") for the reasons discussed below. The ampoules are filled with a specified mixture of H2S and nitrogen and sealed under partial vacuum. The calibration is performed by inserting the sensor into a 700 mL chamber and breaking the ampoule in the closed cylinder. The released mixture from the ampoule diffuses into the closed chamber yielding a concentration of 50 ppm H2S. The detector's output is then adjusted accordingly to ensure accurate measurement of gas leaks in the field application. Pictures of the calibration set up are included as Exhibit 1 and 2. For the following reasons, DEC does not believe that these ampoules pose a significant hazard during transportation. Each ampoule contains 2.5% H2S in a 7 mL ampoule filled under negative pressure of one fifth normal atmospheric pressure. This is equivalent to a concentration of 0.49% as shown by the following equation: 2.5% H2S * 760 Torr 150 Torr = 0.49% H2S ~ ... r , , Subpart D §173.115(c)(2) describes a gas mixture as gas poisonous by inhalation (Division 2.3) when the LCso value is not more than 5,000 mUm. Using the formula defined in §173.133(b)(1 )(i): (100%) (713 ppm) LC50 of a DEC H2S ampoule = = 145,510 mUm3 0.49% Where LCso of H2S =713 ppm (IDLH 7783064 NIOSH)#

Page 4A DET.TRONICS® 6901 West 11Ott! Street Detector Electronies Corporation Minneapolis, MN 55438 USA TeI952.941.5665 Fax 952.829.8750 www.det-tronies.com A UTC Fire & Security Company Thus, the LC50 of each DEC H2S ampoule is 145,510 mUm3 which is significantly greater than the defined 5,000 mUm3 threshold in Section 173.115(c)(2) of the HMR. The packaging for the ampoules is designed for maximum protection to limit breakage during transport. The ampoules are packed in blocks offoam (10 x 10 x 7.5 em), six ampoules to a block (see Exhibit 3). Two foam blocks are packed per corrugated cardboard box (10 x 10 x 15 cm) or a maximum of 12 ampoules per box (see Exhibit 4 and 5). These boxes are then over packed in a box with 300 Ibs. burst strength with additional packing material and/or other items. An MSDS describing the properties and exposure effects of H2S is included with each shipment. Shipments would typically include fewer than 100 ampoules and are not anticipated to exceed 1,000 ampoules. To put this information into context of an example shipment, if 3,000 ampoules (three times the expected maximum shipment) were broken in a 1 m x 1 m x 1 m container with no ventilation, the concentration in the container would reach only 103 ppm. It would take 20,970 ampoules all broken at the same time in a 1m3 container for the concentration to reach the LC50 of 713 ppm. Based on the LC50 value of 145,510 mUm3 per ampoule, the method of packing, and shipment quantities, DEC believes that the ampoules are shipped in a form and quantity that does not pose an unreasonable risk to health and safety or property, and therefore are not classified as hazardous under 49 CFR Parts 170 - 199. The analysis and the classification of ampoules as non-hazardous is consistent with a 1994 letter to General Monitors, Inc. from Edward Mazzullo, Director of the Office of Hazardous Materials Standards. Copies of the General Monitors request, and the response, are attached as Exhibit 6. We are requesting that DOT confirm our assessment regarding the ampoules. Questions regarding the information provided in this letter may be directed to the undersigned at 952 946-6464. Sincerely, ~m~ Director of Engineering Detector Electronics Corporation 6901 West 110th Street Minneapolis, MN 55438 Enclosures#

Page 5Exhibit 1 Ampoule Calibration Set-Up 0.0 8PM A DET TRONICS NTMOS $5 Neq-Flex#

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Page 10Exhibit 6 GMI Letter and DOT Response of Transportation US. Departmens Research and pecial Program dministratio JUl 1 8 001 Mr. Khanh Dang Research Chenist General Monitors, Inc. 26776 simpatica Circle E1 Toro, CA 92630 Dear Mr. Dang: This is in response to your letter of May 5, 1994, requesting ampoules. information on the classification of hydrogen sulfide (HS) You state that each ampoule contains a 1.78ł concentration of HS mixed with nonpressurized nitrogen as a diluent. Each ampoule will of HS in a 250 ml container. Quantities of 12 or 100 ampoules are simulate an exposure of a maximum amount of 500 parts per million dividers. packed in a carton, These cartons are then overpacked in another corrugated with each ampoule packed in corrugated carton, filled with packing material. of the HS, the fact the ampoules are not under pressure, and the It is the opinion of this office that, based on the concentration manner the material is packaged, the ampoules of HS would not pose a significant hazard during transportation and, therefore, are not subject to the Hazardous Materials Regulations (49 CFR Parts 171- 180) • sincerely, Director, Materials Standards Office of Hazardous#

Page 11Exhibit 6 GMI Letter and DOT Response ~~~ I ~l.a.(/"tF:\i~ \'1 132~~ )<J ~ 3~1 May S, 1994 Edward Emazzullo Director ofH.M.S, Office of Hazard Material Standard 400 7th ~t < South West, Room 8100 Washington D.C. 20590 MAY I 8 1994 1/. /..,. Mr. Emazzullo! ,.. 1am writing.this letter in regards to a more current release from DOT concuning with GMI's shipping policy that our HZS ampoules are non·dangerous goods, We already have in our possesSion a letter from Thomas-J; Charlton,- ChiefStandards Division ofDOT, stating that the way we package our HZS ampoules do not pose a significant hazard during transponation(see anached letter). However, this letter is about 12 yeatS old and therefore, I would like to obtain a more current release from DOT. , I would like to take this opponunity to explain why we consider our H2S ampoules as non~angerous goods, First ofall, the ampoules that GMI manufacture contain a very low concentration ofHZS mixed with nitrogen as a dil@. Each ofthese ampoules will simulate an exposure ofa maximum amount of~O pans per million(ppm) HZS in a 250 mL container. According to the lATA 35 Editio~ HZS mlxture less than 14.3% by volume may be classified as ·compressed gas, toxic. n.o.s., UN195S· because the concentration ofHZS is low enough to have a LCSO value higher than 5,000 mUm3 as calculated below ~ lATA Stand.",: MixtureofLC50C> lorffJb~ ~ SOOOmUm3 where LC50 eo 713 ppm (pg.. 280 o(Toxie and lb.zardous, 1985) Mix.tur~ ~~ ~ (l QQ)all~.~ u::;~~ S.OOOmUm GMt's =-mpouln: Concentration o(eacb ampoules.. 7 mL'" (SQ2.Wm)(lSO rot) <:> 17.857 ppm 7m) % Volume per ampoules ~ 17.8S7 ppm c> 1.73% lO,OOOppmfOlo Mixture of LCSO a 009%)(71) ppm) t:f 40.0S6 mlIm3 1.78% • Therefore, GMrs ampoules each contain onJy I 78% onus with an LCSO value of 40,056 mUm3 , which is significantly greater lhan 5,000 mUm3 .#

Page 12does not meet the definition of a Division 2.3 material. Therefore, provided the material does not meet the definition of any other hazard class, it is not subject to the requirements of the HMR. I hope this answers your inquiry. If you need further assistance, please contact this office at 202366-8553. Sincerely, ~i[~ ~ Charles E. Betts . f, Standards Development Office ofHazardous Materials Standards#