{"operation":"document","citation":"12-0104","title":"Hach Company — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2012-06-12","effective_on":null,"summary":"12-0104 response to Hach Company concerning 173.22.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-12-0104.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-12-0104.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-12-0104","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretations/2012/120104.pdf","body":"<<>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n1200 New Jersey Avenue, SE\nWashington, D.C. 20590\n.JUN 1 2 2012\nMs. Dragana Kostic Veneziano\nHach Company\n100 Dayton Ave\nAmes, Iowa 50010\nReference No.: 12-0104\nDear Ms. Kostic Veneziano:\nThis responds to your email dated April 27, 2011 requesting the proper hazard classification\nand description of a solution of granulated calcium hydride suspended in Isooctane under the\nHazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask for\nguidance in selecting a proper shipping description and whether you are permitted to\ndesignate this solution with two separate proper shipping descriptions (\"UN 1404, Calcium\nhydride, 4.3 Packing Group I\" and \"UN 1262, Octanes, 3, Packing Group II\").\nAccording to your email and the supporting test data you provided, the solution of\ngranulated calcium hydride suspended in lsooctane was tested using a Department of\nTransportation (DOT) approved method and was found to meet the classification criteria for\nDivision 4.3 and Class 3.\nAs specified in§ 173.22 of the HMR, it is the shipper's responsibility to properly classify a\nhazardous material. This Office does not generally perform that function. However, based\non your email and supporting test data, it is the opinion of this Office that designating a\nsolution of granulated calcium hydride suspended in lsooctane with two separate proper\nshipping descriptions (\"UN 1404, Calcium hydride, 4.3 Packing Group I\" and \"UN 1262,\nIsooctane, 3, Packing Group II\") is incorrect. Based on your data, it is also the opinion of\nthis Office that \"UN 3482, Alkaline earth metal dispersions, t1ammable, 4.3, (3), Packing\nGroup I\" is the most appropriate proper shipping description as Calcium hydride may be\nconsidered the hydride of an alkaline earth metal and lsooctane is a flammable liquid.\nI hope this satisfies your inquiry. Please contact us if we can be of further assistance.\nSincerely,\nT. Glenn Foster\nChief, Regulatory Review and Reinvention Branch\nStandards and Rulemaking Division\n\n<<>>\n\nDrakeford, Carolyn (PHMSA)\nFrom:\nSent:\nTo:\nSubject: Attachments: INFOCNTR (PHMSA)\nMonday, April 30, 2012 9:14AM\nDrakeford, Carolyn (PHMSA)\nFW: Requesting a Letter of Interpretation\nStresau Test Report. pdf; Picture of the product. pdf; Water in Oil Box.JPG\nHi Carolyn,\nWe received the following request for a letter of interpretation.\nThanks,\nVictoria\nFrom: Kostic, Dragana [mailto:dkostic@Hach.com]\nSent: Friday, April 27, 2012 9:37 AM\nTo: INFOCNTR (PHMSA)\nSubject: Requesting a Letter of Interpretation\nRequest for Letter of Interpretation\nInformation Center\nUS Department of Transportation\ne-mail infocntr@dot.goy\nDear Sir or Madame,\nI am requesting Lette'' of Interpretation for Hach Company product Water in Oil Kit. It\nconsists of 58 glass :est tubes, each containing 8.4 g of granulated calcium hydride\nsuspended in 4.8 ml of isooctane. Test tubes are nested in the covered styrofoam box which\nwould be packed in a fiberboard box. Pictures of the single test tube and the box containing\nthem, are attached. Jhe suspension of calcium hydride in isooctane was tested by the outside\ntesting laboratory using DOT approved method and was found to be hazard class 4.3 and PG I.\nTestini results are al.tached.\nThe reason we ask for interpretation is that none of the DOT available n.o.s. categories seem\nto adequately describ! hazards of this product. Both substances are listed in the Hazardous\nMaterials Table. Pre edence Table designates 4.3 as a primary hazard, and 3 as secondary.\nWe have considered se eral classifications but cannot be sure that any of them exactly\ndescribe the hazards. Below are some of the UN numbers we have looked into:\nWe considered giving this product two separate UN numbers UN1484 4.3 PG I and UN1262 3, PG\nII all packed in one. This could be confusing to customers.\nUN1484 (does not ha· · e subsidiary risk 3)\nUN3132 (subsidiary ,; 4.1, flammable solid, but we have flammable liquid, 3)\nUN3148 (n.o.s. catet·>ry to which we have assigned subsidiary risk of 3, but were told by\nlATA that we cannot a5 .. :ign subsidiary risk if it is not assigned in the Table)\nUN3287 (which has rifht hazard categories but our product is not organometallc). We are not\nsure if «compound dis pt. rsionJJ would be applicable to our product. Technical name would be\n(Calcium hydride immersed in isooctane).\nPlease provide a letter of interpretation as to the appropriate UN number and proper\nshipping name for this product.\n1\n\n<<>>\n\nIf you need additional information or clarification on this product feel free to give me a\ncall.\nBest Regards,\nDragana Kostic Veneziano\nProduct Compliance Chemist\nHach Company\n1ee Dayton Ave\nAmes, Iowa 5001e\nPhone 515-232-2533 (33e8)\ne-mail dkostic@hach.com\nPlease be advised that this email may contain confidential information. If you are not the intended recipient,\nplease notify us by email by replying to the sender and delete this message. The sender disclaims that the\ncontent of this email constitutes an offer to enter into, or the acceptance of, any agreement; provided that the\nforegoing does not invalidate the binding effect of any digital or other electronic reproduction of a manual\nsignature that is included in any attachment.\n2","truncated":false,"body_characters":5341}