{"operation":"document","citation":"10-0244","title":"Ashland, Inc. — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2011-02-08","effective_on":null,"summary":"10-0244 response to Ashland, Inc. concerning 173.21, 177.834.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-10-0244.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-10-0244.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-10-0244","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretations/2010/100244.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration\nFEB 0 8 ZOll\n1200 New Jersey Ave, SE\nWashington, D.C. 20590\nGregory S. Phillips\nGlobal Dangerous Goods Regulatory Process Manager\nAshland, Inc.\n5200 Blazer Parkway, DS-4\nDublin, OH, 43017\nReference No.: 10-0244\nDear Mr. Phillips:\nThis is in response to your request for clarification of the Hazardous Materials Regulations\n(HMR; 49 CFR Parts 171-180) applicable to segregation of hazardous materials. Specifically,\nyou request guidance regarding the transport of Furfuryl alcohol based resins and acid catalysts\non the same transport vehicle. You suggest that there is currently no prohibition in the HMR for\ntransporting these materials together and that the transport of these products together can result\nin a highly exothermic reaction. Your questions and concerns are addressed below.\nThe segregation requirements for transportation by highway specify that hazardous materials\nmay not be loaded, transported, or stored together except as provided in § 177.848. According to\nyour incoming letter and subsequent emails with Rob Benedict of my staff, the Furfuryl alcohol\nbased resin products you transport are \"UN 2874, Furfuryl alcohol, Division 6.1, Packing Group\n(PG) III\" or \"UN 2810, Toxic liquid, organic, n.o.s., Division 6.1, PG III\" while the acid\ncatalysts you transport are \"UN2924, Flammable liquid, corrosive, n.o.s., Class 3, 8, PG III,\"\n\"UN2586, Alkylsulfonic acids, Class 8, PG III\" or \"UN3264, Corrosive liquid; acidic, inorganic,\nn.o.S., Class 8, PG III.\" Based on the classification of these materials, the segregation table\nfound in § 177.848(d) does not explicitly prohibit these products from being transported together\nby highway. However, as specified in § 173.21(e), it is forbidden to offer for transportation or\ntransport \"[a] material in the same packaging, freight container, or overpack with another\nmaterial, the mixing of which is likely to cause a dangerous evolution of heat, or flammable or\npoisonous gases or vapors, or to produce corrosive materials.\" Therefore, regardless of the\nsegregation requirements in § 177.848, if the hazardous materials offered or transported will\ndangerously react when placed together in the same packaging, freight container or overpack\nthey are forbidden to be transported together.\nIn accordance with § 173.22 of the HMR, it is the shipper's responsibility to properly class a\nhazardous material and assign it a proper shipping name from the Hazardous Materials Table\n(HMT; § 172.101). It is also the shipper's responsibility to segregate incompatible hazardous\nmaterials before offering them for transportation in commerce and to determine if the quantity\nand characteristics of those materials offered would cause a dangerous evolution of heat,\n\n<<<PAGE 2>>>\n\nflammable or poisonous vapors if mixed. This Office does not perform that function. However,\nbased on the information and photographs you provided, it is the opinion of this Office that the\nmaterials you described cause a dangerous evolution of heat and should not be transported in the\nsame packaging, freight container or overpack.\nWe recognize the concerns that you have regarding the transport of Furfuryl alcohol based resins\nand acid catalysts on the same vehicle, and we believe that these concerns are sufficiently\naddressed by the HMR as discussed above. However, if you believe that the existing\nrequirements in the HMR are not sufficient, you may submit a petition to amend the HMR in\naccordance with the procedures set forth in 49 CFR Part 106.\nI hope this satisfies your inquiry. Please contact us if we can be of further assistance.\nSincerely,\n,./ Ii, ,i ~,r-\n(,_./, y' tbJZ'.?L/,')?2 ~\nI ~\n~\nT. Glenn Foster\nChief, Regulatory Review and Reinvention Branch\nStandards and Rulemaking Division\n\n<<<PAGE 3>>>\n\n.A45HLAND~\nAshland Inc .\nDS-4\n5200 Blazer Parkway\nDublin, OH 43017\nOffice of Hazardous Materials Standards\nPipeline and Hazardous Materials Safety Administration\nAttn: PHH-I 0\nU.S. Department of Transportation\nEast Building\n1200 New Jersey Avenue, SE.\nWashington, DC 20590-0001\ninfocntr@dot.gov\nNovember lO, 20 I 0\nDear Sirs:\nThis letter is a request for guidance regarding potential hazards associated with the\ntransport of furfuryl alcohol based resins on the same vehicle with acid catalysts.\nAshland Inc. and others manufacture these resin-catalyst systems commonly used in the\nfoundry industry and are often sold as a resin \"system\", i.e. paired products. Our concerns\nlie with the danger oftransporting these resins and catalysts together since they react\nviolently when accidentally mixed. Current hazardous materials segregation requirements\ndo not prohibit transportation of these materials (toxic and corrosive) together. We\nrequest advice regarding how best to manage this issue.\nIn the use ofthis resin system, the resin and the catalyst are mixed together with sand\nwhich mediates the reaction resulting in a harmless chemical bonding process to yield a\nsolid final product. When mixed in the absence of sand, however, a violent exothermic\nreaction results. A small amount ofcatalyst is needed to initiate this highly exothermic\nreaction but the heat produced can instantaneously generate steam leading to an\nexplosion. The heat of reaction itself may provide an ignition source for other flammable\nI combustible materials in the transport vehicle. Reactions typically occur very rapidly\npotentially leading to a hazardous situation within seconds ofmixing. Under certain\ncircumstances, however, the reaction could be delayed for up to twelve hours depending\nupon the resin, acid catalyst and quantities of each. The pictures at the end of this letter\ndepict the results of such a delayed reaction of these materials in a production tank.\nDue to the potential dangers, Ashland Inc. adopted an internal policy prohibiting shipping\nof the furfuryl alcohol based resin and acid catalyst together on the same transport\nvehicle. We believe the only way to avoid such accidental mixing is to ensure that the\ntwo products are not both present in the same vehicle oftransport at the same time.\nUnfortunately, since the hazards presented by shipping the catalyst and resin in the same\nvehicle are not directly addressed under current regulations, there is potential for the\ncatalyst and resin to be simultaneously present on a vehicle when carriers pick up\nmaterial from other companies or when they consolidate freight.\nWe are concerned that vehicle drivers untrained in these specific hazards will be unaware\nof the dangers and that if an accident occurs, and the two products are mixed a hazardous\nAshland Inc. Guidance Request Letter Page 1 of 3\n\n<<<PAGE 4>>>\n\nsituation could rapidly develop endangering the safety of the driver, emergency\nresponders and the community. It is for this reason that we request an opinion from the\nDOT on the practice of shipping the furfuryl acohol based resins and acid catalysts\ntogether on the same transport vehicle. Specifically. is it the opinion ofPHMSA that\nthese materials should not be transported on the same transport vehicle? Could PHMSA\nrecommend special precautions or practices beyond those already being practiced be\ntaken with regard to transportation specific to these materials? Is there a regulatory\nprocess pertaining to situations such as this wherein known hazardous transportation\ncircumstances may exist that are not specifically addressed under the current regulations?\nPlease feel free to contact me directly if you have questions regarding this request, the\nnature ofthe hazards or any other aspect of this issue. I look forward to your response.\nSincerely,\nGregory S. Phillips\nGlobal Dangerous Goods Regulatory Process Manager\nTelephone: 614-790-1603\nAshland, Inc.\n5200 Blazer Parkway, DS-4\nDublin,OH\n43017\nE-mail: gsphillips@ashland.com\nAttachment: Photos of resin blend tanks before and after uncontrolled reaction.\nAshland Inc. Guidance Request Letter Page 2 of 3\n\n<<<PAGE 5>>>\n\nBlend tank before reaction;\nBlend tank after reacti on;\n/\nAshland (nc. Guidanc R quest Letter Page 3 of 3","truncated":false,"body_characters":8114}