UTi — 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 JAN 2 2 2014 Mr. Kathryn Singer UTi 4460 44th Street SE, Suite G Grand Rapids, MI 49512 Ref. No. 13-0186 Dear Ms. Singer: This responds to your September 6, 20 13 email regarding the applicability of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) to the transportation of a motor vehicle lift system powered by a wet acid battery. In your letter, you indicate that the battery is installed in the system when shipped and that the system is shipped upright with protective material around the system. You also provide a safety data sheet for the battery, images of the system, and a web link to a video showing the installed battery. No other hazardous material is contained in the system. Thus, your understanding is that the system as described and shown would not be subject to the HMR when you transport it by highway, rail and vessel. In accordance with§ 173.22, it is the shipper's responsibility to ensure compliance with the requirements of the HMR. The system you describe is considered battery-powered equipment, which is eligible for exception from the HMR under§ 173.220. In accordance with§ 173.220(c), a wet battery must be securely installed and fastened in an upright position. The battery must also be protected against a dangerous evolution of heat, short circuit, damage to terminals, and leakage. Battery-powered equipment meeting these conditions, containing no other hazardous material and transported by highway, rail or vessel is not subject to the HMR (except for the forbidden conditions of § 1 73 .21 applicable to batteries). Based on the information you provided, it is the opinion of this Office that the motor vehicle lift system would not be subject to the HMR. I hope this information is helpful. If you have further questions, please contact this office. Sincerely, Robert Benedict Chief, Standards Development Branch Standards and Rulemaking Division#

Page 2Der k.inderen § 17?>· J_;L() Drakeford, Carolyn (PHMSA) From: INFOCNTR (PHMSA) Alla.chrnevy Sent: Friday, September 06, 2013 2:55 PM To: Drakeford, Carolyn (PHMSA) Subject: FW: Request Formal Letter of Interpretation /3- /) ltb Attachments: SDOC8732-MSDS.PDF; DSC05183.jpg; DSC05184.jpg; MACH4_Brochure_VIEW_2012.06.pdf Hi Carolyn, This caller requested we submit this e-mail as a formal letter of interpretation. Thanks, Victoria From: Singer, Kathryn [mailto:KSinger2@go2uti.com] Sent: Friday, September 06, 2013 1:50PM To: INFOCNTR (PHMSA) Subject: Request Formal Letter of Interpretation Good afternoon, On behalf of my customer, Vehicle Service Group in Madison Indiana, I wish to request a formal letter of interpretation for the Rotary Lift Mach Vehicle Lift System. This product is currently shipping with the following identification on the Bill of Lading along with Class 8 Corrosive placards: "BATIERIES WET FILLED WITH ACID 8 UN2794 PGIII" This Vehicle Lift contains an installed battery when shipped. The MSDS sheet for the installed battery is attached. The battery is housed within the unit and ships installed. Images of the lift are also attached along with the product brochure. The following video shows the features and operation with a look at the bracketed installation of the battery at 38 seconds in. http:ljwww.youtube.com/watch?v=z6UZtT4U95w&list=UURyCg3 TgUVZe9KwqpbPjWA The 4, 6 or 8 columns are shipped as a single unit depending the actual SKU orders. They are shipped upright with protective shipping material around the column. , We have been advised by our carriers that this item does not require HAZMAT identification. We utilize multiple transportation for these lifts: full truckload, less-than-truckload, rail and ocean. Please provide a Formal Letter of Interpretation for this lift stating whether this product requires HAZMAT certification or can ship as non-HAZMAT without placards or identification on the BOL for all of the modes we are using. Please contact me if you have further questions. Best Regards, Katie Singer Kathryn Singer- Account Manager UTi 14460 44th Street S.E. Suite G (49512) I Grand Rapids I Michigan 1495121 USA ksinger2@go2uti.com 1 0 +1.616.855.12751 F +1 616.988.5910 1 C +1.616.238.8100 1#

Page 3Important Notice. This email message contains information which may be confidential and/or legally privileged. Unless you are the intended recipient (or have been authorised to receive on behalf of the intended recipient), you may not use, copy or disclose to anyone the message or any information contained in the message or from any attachments that were sent with this email. If you have received this email message in error, please advise the sender by email, and delete the message. 2#

Page 4TECHNOLOGIES MATERIAL SAFETY DATA SHEET I. PRODUCT IDENTIFICATION MANUFACTURER CHEMJCAUTRADE NAME Lead-Acid Battery Exide Technologies (as used on label) 13000 Deerfield Parkway, Bldg. 200 Alphareua, GA 30004 CHEMJCAL FAMIL Yf FOR INFORMATION CLASSIFICATION Primary: MACTEC Engineering and Consulting, Inc. Attention: Juliann Cothran (770) 421-3485 Secondary: Environmental, Safety & Health DATE ISSUED: Attention: Eric Murray (800) 523-4622 Fred Ganster (610) 921-4052 Electric Storage Battery February I, 2008 Page 1 of5 FOR EMERGENCY CHEMTREC (800) 424-9300 24-hour Emergency Response Contact Ask for Environmental Coordinator CHEMTREC JNTERNA TIONAL (703) 527-3887- Collect 11. HAZARDOUS INGREDIENTS/IDENTITY INFORMATION Approximate Air Exposure Limits (!Jgfm') Components CAS Number %byWt. OSHA ACGIH NIOSH · Itiorganic compounds of: ,. .. ' .. :-·~ .. · •... -~-- .. , -.~,-·.<··;.· > •.. Lead 7439-92-1 54-62 50 50 50 Antimony 7440-36-0 0.4 500 500 500 Tin 7440-31-5 0.16 2000 2000 2000 Calcium 7440-70-2 0.02 - - - Arsenic 7440-38-2 0.01 10 10 2 Electrolyte (sulfuric acid/water/solution) 7664-93-9 26-40 1000 200 1000 Case Material: Polypropylene 9003-07-0 5-12 N/A N/A N/A Hard Rubber -- Plate separator material: Polyethylene 9002-88-4 1-2 N/A N/A N/A NOTE: Inorganic lead and electrolyte (water and sulfuric acid solution) are the primary components of every battery manufactured by Exide Technologies or its subsidiaries. Other ingredients may be present dependent upon battery type. Polypropylene is the principal case material of automotive and cmnmercial batteries. III. PHYSICAL DATA- ELECTROLYTE Boiling Point 203" F-240" F (for S.G. mnge) Specific Gravity (H20= I) 1.230 to 1.350 Melting Point Not Applicable Vapor Pressure 17 to 11 (for S.G. range) Solubility in Water 100% (mmHg) 77" F Evaporation Rate Less Than I Vapor Density (AIR= I) Greater than l (Butyl acetate= I) Appearance and Odor % Volatiles by Weight Not Applicable A clear liquid with a sharp, penetrating, pungent odor. A battery is a manufactured article; no apparent odor. IV. FIRE AND EXPLOSION HAZARD DATA Flash Point: Not Applicable Finmmable Limits: LEL = 4.1% (Hydrogen Gas in air); UEL = 74.2% Extinguishing media: C02; foan1; dry chemical Special Fire Fighting Procedures: Use positive pressure, self-contained breathing apparatus. Beware of acid splatter during water application and wear acid-resistant clothing, gloves, face and eye protection. If batteries are on charge, shut off power to the charging equipment. but, note that strings of series connected batteries may still pose risk of electric shock even when charging equipment is shut down. Page 1 of5#

Page 5IV. FIRE AND EXPLOSION HAZARD DATA (CONTINUED) Unusual Fire and Explosion Haz.1rds: In opemlion, batteries generate and release flammable hydrogen gas. They must always be assumed to contain this gas which, if ignited by burning cigarette, naked flame or spark, may cause battery explosion with dispersion of casing fmgments and corrosive liquid electrolyte. Carefully follow manufacturer's instructions for installation and service. Keep away all sources of gas ignition and do not allow metallic articles to simultaneously contact the negative and positive tenninals of a battery. V. REACTIVITY DATA Stability: Stable ...1L Unstable_ Conditions to Avoid: Prolonged overcharge at high current; sources of ignition. Incompatibility: (materials to avoid) Electrolyte: Contact wil11 combustibles and organic materials may cause fire and explosion. Also reacts violently with strong reducing agents, metals, sulfur trioxide gas, strong oxidizers, and water. Contact with metals may produce toxic sulfur dioxide fumes and may release Oammable hydrogen gas. Lead compounds: Avoid contact with strong acids, bases, halides, halogenates, potassium nitrate, perrnanganate, peroxides, nascent hydrogen, and reducing agents. Hazardous Decomposition Products: Electrolyte; Sulfur trioxide, carbon monoxide, sulfuric add mist, sulfur dioxide, hydrogen su1fide. Lead compounds: Temperatures above the melting point are likely to produce toxic metal fume, vapor, or dust; contact wiili strong acid or base or presence of nascent hydrogen may generate highly toxic arsine gas. VI. HEALTH HAZARD DATA''···· ········- ·· · ·· ·· Routes of Entry: Electrolvte: Harmful by all routes of entry. Lead compounds: Hazardous exposure can occur only when product is heated above the melting point, oxidized or otherwise processed or damaged to create dust, vapor, or fume. Inhalation: Electrolvte: Breathing of sulfuric acid vapors or mists may cause severe respiratory irritation. Lead compounds: Inhalation of lead dust or fumes may cause irritation of upper respiratory tmct and lungs. Ingestion: Electrolvte: May cause severe irritation of mouili, throat, esophagus, and stomach. Lead compounds: Acute ingestion may cause abdominal pain, nausea, vomiting, diarrhea, and severe cmmping. TI1is may lead rapidly to systemic toxicity. Sldn Contact: Electrolyte: Severe irritation, bums, and ulcemtion. Lead compounds: Not absorbed through the skin. Eye Contact: Electrolvte: Severe irritation. bums, cornea dlunage, blindness. Lead compounds: May cause eye irritation. E&Tects of Overexposure· Acute: -------------- Eiectrolvte: Severe skin irritation, damage to cornea may cause blindness, upper respiratory irritation. Lead compounds: Symptoms of toxicity include headache, fatigue, abdominal pain, loss of appetite, muscular aches and weakness. sleep disturbances, and irritability. Enccts of Overexposure - Chronic: Electrolyte: Possible erosion of tooth enamel; inflammation of nose. throat, and bronchial tubes. Page 2 of5#

Page 6VI. HEALTH HAZARD DATA (CONTINUED) Lead compounds: Anemia; neuropathy, particularly of the motor nerves, with wrist drop; kidney damage; reproductive changes in both males and females. Carcinogenicity: Electrolvtc: Tile National Toxicology Program (NTP) and the Intemational Agency for Research on Cancer (lARC) have classified "·strong inorganic acid mist conwining sulfuric add" as a substance that is carcinogenic 10 humans. TI1is classification does not apply to sulfuric acid solutions in static liquid state or to electrolyte in batteries. Batteries subjected to abusive charging at excessively high currents for prolonged periods of lime without vent caps in place may create a surrounding atmosphere of the offensive strong inorganic acid mist containing sulfuric acid. Lead compounds: Listed as a 2B carcinogen, likely in animals at extreme doses. Proof of carcinogenicity in httrr)ans is lacking at present Arsenic: Listed by International Agency for Research on Cancer (IARC), OSHA and NIOSH ar; a carcinogen only after prolonged exposure at high levels. Medical Conditions Generally Aggravated by Exposure: Overexposure to su1furic acid mist may cause lung damage and aggr .. wate pulmonary conditions. Contact of electrolyte (water and sulfuric acid solution) with skin may aggravate skin diseases such as eczema and contact dermatitis. Contact of electrolyte (water und sulfuric acid solution) with eyes may damage comen and/or cause blindness. Lead and its compounds can aggravate some forms of kidney, liver, and neurologic diseases. Emergency and First Aid Procedures Inhalation: Electrolyte: Remove to fresh air immediately. If breathing is difficult, give oxygen. Lead compounds: Remove from exposure, gargle, wash nose and lips; consult physician. . ... . . .. "' ,, .. ·--~-" -.· . ,. ·-···~ ... - .. Ingestion: ElectroMe: Give large quantities of water; do not induce vomiting; consult physician. Lead compounds: Consul! physician immediately. Sldn: Electrolyte: Rush with large amounts of water for at least 15 minutes; remove contaminated clothing completely. including shoes. Lead compounds: Wash immediately with soap and water. Eyes: Electrolvte and Lead compounds: Flush immediately with large amounts of water for at least 15 minutes; consult physician immediately. Vll. PRECAUTIONS FOR SAFE HANDLING AND USE Handling and Storage: Store batteries under roof in cool, dry, well-ventilated areas that arc separated from incompatible materials and from activities that muy create flames, spark. or heat Store on smooth, impervious surfaces that are provided with measures for liquid containment in the event of electrolyte spills. Keep away from metallic objects that could bridge the terminals on a battery and create a dangerous short-circuit Handle carefully and avoid tipping, which may allow electrolyte leakage. Single batteries pose no risk of electric shock but there may be increasing risk of electric shock from strings of connected batteries exceeding three 12-volt units. Charging: There is u possible risk of electric shock from charging equipment and from strings of series connected batteries, whether or not being charged. Shut-off power to churgers whenever not in use and before detachment of any circuit connections. Batteries being charged will genero~te and release flammable hydrogen gas. Charging space should be ventilated. Keep battery vent caps in position. Prohibit smoking and avoid creation of flames and sparks nearby. Wear face and eye protection when ncar batteries being cllllrged. Spill ur Leak Procedures: Stop flow of material, contain/absorb small spills with dry sand, earth, and venniculite. Do not use combustible materials. If possible, carefully neutralize spilled electrolyte with soda ash, sodium bicarbonate, lime, etc. Wear acid-resistant clothing, boot~. gloves, and face shield. Do not allow discharge of un-neutralized acr'd to sewer. Neutralized acid must be managed in accordance with approved local, state, and federal requirements. Consult stale environmental agency and/or federal EPA. Waste Disposal Methods: Spent batteries: Send to secondary lead smeller for recycling. Page 3 of5 ---- ---·------··-----·~- ··-~------·----#

Page 7VII. PRECAUTIONS FOR SAI<'E HANDLING AND USE {CONTINUED) Electrolyte: Place neutralized slurry into sealed acid resistant containers and dispose of as hazardous waste, as applicable. Large water diluted spills, after ncutmlization and testing, should be m;magcd in accordance with approved local, state, and federal requirements. Consult stale environmental agency and/or federal EPA. Precautionary Labeling: POISON • CAUSES SEVERE BURNS DANGER - EXPLOSIVE GASES CORROSIVE- CONTAINS SULFURIC ACID KEEPAWAY FROM CHILDREN VITI. CONTROL MEASURES Engineering Controls and Work Practices: Store and handle in well-ventilated area. If mechanical ventilation is used, components must he acid-resistant Handle batteries cautiously, do not tip to avoid spills. Make certain vent caps are on securely. If battery cao;;e is damaged, avoid bodily conttlct with internal components. Wear protective clothing, eye and face protection, when filling, charging, or handling batteries. Respiratory Protection: None required under normal conditions. When eoncentmtions of sulfuric acid mist are known to exceed PEL, use NIOSH or MSHA-approved respirdtory protection. Protective gloves: Rubber or plastic acid-resistant gloves with elbow-length gauntlet. Eye Protection: Chemical goggles or face shield. Other Protection: ~(:id~~cs!.~~~~-~p~ol\: :~ndcr severe exposure or emergency conditions, wear acid-resistant clothing, gloves, and boots. Emergency Flushing: In areas where water and sulfuric acid solutions are handled in concentmtions greater than 1%, emergency eyewa~h stations and showers should be provided, with unlimited water supply. IX. OTHEU REGULATORY INFORMATION ..., .. -... :-:. NFPA Hazard Rating for sulfuric acid: FliUl'lmability (Red) = 0 Health (Blue) = 3 Reactivity (Yellow) "" 2 Sulfuric acid is water-reactive if concentrated. TRANSPORTATION: Wet (filled with electrolyte) batteries are regulated by U.S. DOT as a hazardous material, as provided in 49 CFR 173.159 Proper Shipping Name: Battery, wet, filled with acid Hazard Class/Division: 8 ID Number: UN2794 Packing Group: III Label Required: Corrosive RCRA: Spent lead-acid batteries arc not regulated as hazardous waste when recycled. Spilled sulfuric acid is a characteristic hazardous waste; EPA hazardous waste number 0002 (corrosivity). CERCLA (Superfund) and EPCRA: (a) (b) Reportable Quantity (RQ) for spilled 100% sulfuric acid under CERCLA (Superfund) and EPCRA (Emergency Planning and Community Right to Know Act) is 1,000 Jbs. State and local reportable quantities for spi11ed sulfuric acid may vary. Sulfuric acid is a listed "Extremely Hazardous Substance" under EPCRA, witll a Threshold Planning Quantity {TPQ) of 1,000 (c) (d) lbs. EPCRA Section 302 notification is required if 1,000 lbs or more of sulfuric acid is present at one site. An average automotive/commercial battery contains approximately 5lbs of sulfuric acid. Contact your Exide representative for additional infom1ation. EPCRA Section 312 Tier Two reporting is required for non-automotive batteries if sulfuric acid is present in quantities of 500 lbs or more and/or if lead is present in quantities of 10,000 lbs or more. Page4 of5#

Page 8(e) IX. OTHER REGULATORY IN1"0RMAT10N (CONTINUED) Supplier Notification: This product contains toxic chemicals that may be reportable under EPCRA Section 313 Toxic Chemical Release Inventory (Form R) requirements. For a manufacturing facility under SIC codes 20 through 39, the following information is provided to enable you to complete the required reports: Approximate Toxic Chemical CAS Number % bv Weight Lead 7439-92-1 54-62 Sulfuric Acid/Water Solution 7664-93-9 26-40 'ltAntjmony 7440-36-0 0.4 *Arsenic 7440-38-2 0.01 *Not present in all baltery types. Contact your Exide representative for additional infom1ation. If you distribute this product to other manufacturers in SJC Codes 20 through 39, this information must be provided with the first shipment of each calendar year. Note: Tile Section 313 supplier notification requirement docs not apply to batteries that are "consumer products". CAA: Exide Technologies supports preventative actions concerning ozone depletion in the atmosphere due to emissions of CFC's and other ozone depleting chemicals {ODC's), defined by the USEPA as Class I substances. Pursuant to SectionoTrOfl.hel:lean Air Act Amendments (CAAA) of 1990, finalized on January 19, 1993, Exide established a policy to elimimlle the usc of Class I ODC's prior to the May 15, 1993 deadline. TSCA: ... ,., .. ,·, .. ,. ..... ·. Ingredients in Exide's batteries are listed in tl1c TSCA Registry as follows: CAS NO . 7664-93-9 TSCA Status Listed Electrolyte: Sulfuric acid (H2S04) Inorganic Lead Compound Lead (Pb) Lead Oxide (PbO) Lead Sulfate (PbS0.1 ) Amimony (Sb) Arsenic (As) Calcium (Ca) Tin (Sn) 7439-92-1 1317-36-8 7446-14-2 7440-36-0 7440-38-2 7440-70-2 7440-31-5 Listed Listed Listed Listed Listed Listed Listed CANADIAN REGULATIONS: All chemical substances in this product are listed on the CEPA DSUNDSL or are exempt from list requirements. CALIFORNIA PROPOSITION 65: "WARNING: This product contains lead, a chemical known to the State of California to cause cancer. or birth defects or other reproductive harm." PREPARED BY: ENViRONMENTAL, SAFETY AND HEALTH DEPARTMENT - --- · · · EXIDE TECHNOLOGIES -- · ~ -- - 13000 DEERFIELD PKWY., BLDG. 200 ALPHARETTA, GA 30004 VENDEE AND TI-ilRD PERSONS ASSUME THE RISK OF INJURY PROXIMATELY CAUSED BY THE MATERIAL IF REASONABLE SAFETY PROCEDURES ARE NOT FOLLOWED AS PROVIDED FOR IN THE DATA SHEET, AND VENDOR SHALL NOT BE LIABLE FOR INJURY TO VENDEE OR THIRD PERSONS PROXIMATELY CAUSED BY ABNORMAL USE OF THE MATERlAL EVEN 1F REASONABLE PROCEDURES ARE FOLLOWED. ALL PERSONS USING THIS PRODUCT, ALL PERSONS WORKING IN AN AREA WHERE THJS PRODUCT IS USED, AND ALL PERSONS HANDLING THIS PRODUCT SHOULD BE FAMILIAR \VlTH THE CONTENTS OF THIS DATA SHEET. THlS INFORMA T!ON SHOULD BE EFFECTNELY COMMUNICATED TO EMPLOYEES AND OTHERS WHO MIGHT COME IN CONTACT WITH THE PRODUCT. WHILE THE INFORMATION ACCUMULATED AND SET FORTI-! HEREIN lS BELIEVED TO BE ACCURATE AS OF THE DATE HEREOF, EXlDE TECHNOLOGIES MAKES NOW ARRANTY WITH RESPECT THERETO AND DISCLAIMS ALL LIABILITY FROM REL1ANCE THEREON. RECIPIENTS ARE ADVISED TO CONFIRM IN ADVANCE OF NEED THAT THE INFORMATION IS CURRENT, APPLICABLE. AND SUITABLE FOR THEIR PARTICULAR CiRCUMSTANCES. ANY PHOTOCOPY MUST BE OF TI-llS ENTIRE DOCUMENT Page 5 of5#

Page 9I ROTARY LIFT#

Page 10& ROTARY LIFT (ROTARY LIFT#