Hach Company — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Avenue, SE Washington, D.C. 20590 .JUN 1 2 2012 Ms. Dragana Kostic Veneziano Hach Company 100 Dayton Ave Ames, Iowa 50010 Reference No.: 12-0104 Dear Ms. Kostic Veneziano: This responds to your email dated April 27, 2011 requesting the proper hazard classification and description of a solution of granulated calcium hydride suspended in Isooctane under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask for guidance in selecting a proper shipping description and whether you are permitted to designate this solution with two separate proper shipping descriptions ("UN 1404, Calcium hydride, 4.3 Packing Group I" and "UN 1262, Octanes, 3, Packing Group II"). According to your email and the supporting test data you provided, the solution of granulated calcium hydride suspended in lsooctane was tested using a Department of Transportation (DOT) approved method and was found to meet the classification criteria for Division 4.3 and Class 3. As specified in§ 173.22 of the HMR, it is the shipper's responsibility to properly classify a hazardous material. This Office does not generally perform that function. However, based on your email and supporting test data, it is the opinion of this Office that designating a solution of granulated calcium hydride suspended in lsooctane with two separate proper shipping descriptions ("UN 1404, Calcium hydride, 4.3 Packing Group I" and "UN 1262, Isooctane, 3, Packing Group II") is incorrect. Based on your data, it is also the opinion of this Office that "UN 3482, Alkaline earth metal dispersions, t1ammable, 4.3, (3), Packing Group I" is the most appropriate proper shipping description as Calcium hydride may be considered the hydride of an alkaline earth metal and lsooctane is a flammable liquid. I hope this satisfies your inquiry. Please contact us if we can be of further assistance. Sincerely, T. Glenn Foster Chief, Regulatory Review and Reinvention Branch Standards and Rulemaking Division#

Page 2Drakeford, Carolyn (PHMSA) From: Sent: To: Subject: Attachments: INFOCNTR (PHMSA) Monday, April 30, 2012 9:14AM Drakeford, Carolyn (PHMSA) FW: Requesting a Letter of Interpretation Stresau Test Report. pdf; Picture of the product. pdf; Water in Oil Box.JPG Hi Carolyn, We received the following request for a letter of interpretation. Thanks, Victoria From: Kostic, Dragana [mailto:dkostic@Hach.com] Sent: Friday, April 27, 2012 9:37 AM To: INFOCNTR (PHMSA) Subject: Requesting a Letter of Interpretation Request for Letter of Interpretation Information Center US Department of Transportation e-mail infocntr@dot.goy<mailto:infocntr@dot.gov> Dear Sir or Madame, I am requesting Lette'' of Interpretation for Hach Company product Water in Oil Kit. It consists of 58 glass :est tubes, each containing 8.4 g of granulated calcium hydride suspended in 4.8 ml of isooctane. Test tubes are nested in the covered styrofoam box which would be packed in a fiberboard box. Pictures of the single test tube and the box containing them, are attached. Jhe suspension of calcium hydride in isooctane was tested by the outside testing laboratory using DOT approved method and was found to be hazard class 4.3 and PG I. Testini results are al.tached. The reason we ask for interpretation is that none of the DOT available n.o.s. categories seem to adequately describ! hazards of this product. Both substances are listed in the Hazardous Materials Table. Pre edence Table designates 4.3 as a primary hazard, and 3 as secondary. We have considered se eral classifications but cannot be sure that any of them exactly describe the hazards. Below are some of the UN numbers we have looked into: We considered giving this product two separate UN numbers UN1484 4.3 PG I and UN1262 3, PG II all packed in one. This could be confusing to customers. UN1484 (does not ha· · e subsidiary risk 3) UN3132 (subsidiary ,; 4.1, flammable solid, but we have flammable liquid, 3) UN3148 (n.o.s. catet·>ry to which we have assigned subsidiary risk of 3, but were told by lATA that we cannot a5 .. :ign subsidiary risk if it is not assigned in the Table) UN3287 (which has rifht hazard categories but our product is not organometallc). We are not sure if «compound dis pt. rsionJJ would be applicable to our product. Technical name would be (Calcium hydride immersed in isooctane). Please provide a letter of interpretation as to the appropriate UN number and proper shipping name for this product. 1#

Page 3If you need additional information or clarification on this product feel free to give me a call. Best Regards, Dragana Kostic Veneziano Product Compliance Chemist Hach Company 1ee Dayton Ave Ames, Iowa 5001e Phone 515-232-2533 (33e8) e-mail dkostic@hach.com Please be advised that this email may contain confidential information. If you are not the intended recipient, please notify us by email by replying to the sender and delete this message. The sender disclaims that the content of this email constitutes an offer to enter into, or the acceptance of, any agreement; provided that the foregoing does not invalidate the binding effect of any digital or other electronic reproduction of a manual signature that is included in any attachment. 2#