# Patterson Companies, Inc — Hazardous Materials Safety Interpretation

- **operation:** document
- **citation:** 14-0008
- **title:** Patterson Companies, Inc — Hazardous Materials Safety Interpretation
- **source type:** guidance
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** guidance
- **official:** true
- **published on:** 2014-07-29
- **effective on:** Not available
- **summary:** 14-0008 response to Patterson Companies, Inc concerning 173.132, 173.133.
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-interpretation-14-0008.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-interpretation-14-0008.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-interpretation-14-0008
- **source url:** https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2014/140008.pdf
**body:**

<<<PAGE 1>>>

U.S. Department
1200 New Jersey Avenue, SE
of Transportation
Washington, D.C. 20590
Pipeline and Hazardous
Administration
Materials Safety
JUL 2 9 2014
Robb Boros
Regulatory Compliance Specialist
Patterson Companies, Inc.
1905 Lakewood Drive
Boone, Iowa 50036
Ref. No.: 14-0008
Dear Mr. Boros:
This responds to your January 10, 2014 letter requesting clarification of the term maximum
attainable concentration concerning inhalation toxicity for Division 6.1 poisonous materials
under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).
According to the information in your letter and the material safety data sheet (MSDS) you
provided, you have identified your material as Halamid® with chemical names of Benzene
sulfonamide, N-Chloro-4-methyl, or sodium salt; synonyms of Sodium p-
Toluenesulfonchloramide or Chloramine-T; and C.A.S. Registry Numbers of 127-65-1
(anhydrous) / 7080-50-4 (trihydrate)'. Further, the MSDS classified the material as
"UN3263, Corrosive solid, basic, organic, n.o.s. (Sodium p-toluenesulfonchloramide), 8, PG
III." Also, the acute toxicity test data values provided in the MSDS and used in the
classification are as follows:
Inhalation toxicity by dusts and mists LC50 (mg/L): Acute exposure: The acute 4 hr. LCso for
this product in rats is greater than 0.275 mg/L (maximum attainable dust concentration).
Dermal toxicity LD50 (mg/kg): Acute contact: Dermal toxicity (LDso) is greater than 2,000
mg/kg in rabbits (8% solution). The pure powder form of Halamid® is corrosive to rabbit
skin following a 4 hour exposure period while an 8% solution is not irritating to skin.
Oral toxicity LD50 (mg/kg): Acute exposure: The oral LDso for this material is approximately
1,000 mg/kg (rat/mice).
' Provided in the MSDS, the anhydrous substance (CAS# 127-65-1) covers all hydrated forms of this product.
The trihydrate substance (CAS# 7080-50-4) is the only commercially available and chemically stable form of
Sodium p-Toluenesulfonchloramide.

<<<PAGE 2>>>

Finally, in your letter you provide a link to an Organization for Economic Cooperation and
Development (OECD) document entitled "OECD Guideline for the Testing of Chemicals?
which discusses guidelines for testing of acute inhalation toxicity materials. Your questions
are paraphrased and answered below.
Q1: You ask what the term "maximum attainable concentration" means in paragraph 30,
page 7, of the Revised OECD Guideline 403 (Acute Inhalation Toxicity):
Al: As provided in the OECD guideline, the protocol for the limit test states:
A limit test is used when the test article is known or expected to be virtually non-toxic,
i.e., eliciting a toxic response only above the regulatory limit concentration. In a limit
test, a single group of three males and three females is exposed to the test article at a
limit concentration. Information about the toxicity of the test material can be gained
from knowledge about similar tested compounds or similar tested mixtures or
products, taking into consideration the identity and percentage of components known
to be of toxicological significance. In those situations where there is little or no
information about its toxicity, or the test material is expected to be toxic, the main test
should be performed
The selection of limit concentrations usually depends on regulatory requirements.
When the GHS Classification System is used, the limit concentrations for gases,
vapours, and aerosols are 20,000 ppm, 20 mg/L, and 5 mg/L, respectively (or the
maximum attainable concentration). It can be technically challenging to generate limit
concentrations of some test articles, especially as vapours and aerosols. When testing
aerosols, the primary goal should be to achieve a respirable particle size (MMAD of
1-4 jim). This is possible with most test articles at a concentration of 2 mg/L. Aerosol
testing at greater than 2 mg/L should only be attempted if a respirable particle size
can be achieved (see GD 39). GHS discourages testing in excess of a limit
concentration for animal welfare reasons (3). The limit concentration should only be
exceeded when there is a compelling reason, such as a direct relevance to the
protection of human health, and the reason must be explained in the study report. In
the case of potentially explosive test articles, care should be taken to avoid conditions
favourable for an explosion. To avoid an unnecessary use of animals, a test run should
be conducted prior to the limit test to ensure that the chamber conditions for a limit
test can be achieved.
If mortality or moribundity is observed at the limit concentration, the results of the
limit test can serve as a sighting study for further testing at other concentrations (see
main study). If a test article's physical or chemical properties make it impossible to
attain a limit concentration, the maximum attainable concentration should be tested.
If less than 50% lethality occurs at the maximum attainable concentration, no further
testing is necessary. The study report should contain an explanation and supportive
^ Organization for Economic Co-operation and Development (OECD) Guideline for the Testing of Chemicals,
http://www.eecd.org/chemicalsafety/testing/41761261.pdf
Draft Proposal for a Revised Guideline 403, Acute Inhalation Toxicity,
2

<<<PAGE 3>>>

data for why the limit concentration could not be attained. If the maximum attainable
concentration of a vapour does not elicit toxicity, it may be necessary to generate the
test article as a liquid aerosol.
The "maximum attainable concentration" is the greatest amount of test material that
can be suspended and maintained in the air in an inhalation chamber to test for acute
inhalation toxicity in conformance with the methods prescribed in OECD Guideline
403.
Q2: You seek clarification on the MSDS's usage of "maximum attainable dust
concentration" for the LCso inhalation toxicity, and whether the material meets a
Division 6.1 definition and assignment of packing group as prescribed in §§ 173.132
and 173.133.
A2: Under § 173.22 of the HMR it is a shipper's responsibility to properly classify a
hazardous material. This Office does not generally perform that function. However,
based on the test results provided in the MSDS, it is the opinion of this Office that the
material does not meet the LCso criteria for acute inhalation toxicity.
The HMR defines a poisonous material in § 173.132 as a material, other than a gas,
that is known to be toxic to humans because it falls within one of the following
categories when tested on laboratory animals: oral toxicity, dermal toxicity, and
inhalation toxicity. Included in the definition under § 173.132(a)(1)(iii) for inhalation
toxicity, if a dust or mist has an LCso of not more than 4 mg/L then it meets the
Division 6.1 criteria. If the MSDS for Halamid® you provided is accurate and the
"maximum attainable concentration" of 0.275 mg/L is not toxic, it is the opinion of
this Office that this material would not meet the definition of a Division 6.1 material
in addition to any other hazard class the material might meet. As such, the description
"UN3263, Corrosive solid, basic, organic, n.o.s. (Sodium p-toluenesulfonchloramide),
8, PG III" is appropriate.
I trust this satisfies your inquiry. Please contact us if we can be of further assistance.
Sincerely,
Ann taster
T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division
3

<<<PAGE 4>>>

Nickels
$172.101
Drakeford, Carolyn (PHMSA)
$ 173.226
Sent:
From:
Nickels, Matthew (PHMSA)
3173.221
To:
Friday, January 10, 2014 11:38 AM
Cc:
Drakeford, Carolyn (PHMSA)
Applicability
Subject:
Foster, Glenn (PHMSA)
Attachments:
FW: New Interp Request
14-0008
Halamid_Chloramine_T_MSDS_2005-0218.pdf
Importance:
High
Hey Carolyn, as soon as you get a chance, please take this submitted e-mail as a new formal letter of interpretation
request; and assign it to me.
Thanks, Matt
From: robb.boros@pattersoncompanies.com [mailto:robb.boros@pattersoncompanies.com]
Sent: Friday, January 10, 2014 10:39 AM
To: Nickels, Matthew (PHMSA)
Subject: New Interp Request
http://www.oecd.org/chemicalsafety/testing/41761261.pdf
Check out page 7, item 30.
I am looking to get clarification regarding "maximum attainable concentration" with regards to inhalation toxicity.
If a chemical has a maximum attainable concentration less than or equal to 4.0mg/L, and death does not occur in at least
to inhalation toxicity or is the chemical considered not toxic by inhalation?
50% of the population of rats at that concentration, does there need to be any further considerations made regarding solely
For example, we distribute a product that is comprised of 90-100% Chloramine-T. The toxicity data indicates the product
has an inhalation value (LC50 - rat) identified as being greater that 0.275 mg/L for a 4-hour exposure, and specifies this is
the maximum attainable concentration. I have been unable to find any reference in the HMR regarding maximum attainable
concentrations, nor have I found any guidance in existing interpretations.
Thanks
Robb Boros
Patterson Companies, Inc.
Regulatory Compliance Specialist
515.433.1700 (Fax 1701)
otherwise exempt from disclosure under applicable law and is intended solely for the use of the individual(s) to whom it was
NOTICE: This email transmission and any attachments that accompany it may contain information that is confidential or
dissemination, distribution, copying or other use or retention of this communication or its substance is prohibited. If you
intended to be addressed. If you have received this email by mistake, or you are not the intended recipient, any disclosure,
have received this communication in error, please immediately report to the author via email that you received this message
by mistake and also permanently destroy printed copies and delete the original and all copies of this email and any
attachments from your computer.
1

<<<PAGE 5>>>

axcentive
Material Safety Data Sheet
HALAMID®
SECTION 1. CHEMICAL PRODUCT AND COMPANY INFORMATION
Product Name:
HALAMID ®
Chemical Name:
Benzene sulfonamide, N-Chloro-4-methyl, sodium salt
Synonyms:
Sodium p-Toluenesulfonchloramide ; Chloramine-T
C.A.S. Registry No.:
127-65-1 (anhydrous) / 7080-50-4 (trihydrate) [See additional information in Sections 3 and 15]
Chemical Formula:
Cy Hy Cl N NaO_S (and hydrates)
Product Use:
Oxidizing agent
Axcentive SARL
Manufacturer / Supplier
Chemin de Champouse
13320 Bouc Bel Air, France
Tel. (33) 442 694 090
Emergency Telephone Number: (011) 31 570 679211 (Akzo Nobel Chemicals, Deventer, The Netherlands)
Date of First Issue:
September 24, 2004
Revision No.:
2.0
Revision Date:
February 18, 2005
Changes:
Sections 1, 2, 4, 11, 15
SECTION 2. HAZARDS INFORMATION
EMERGENCY OVERVIEW
This material is considered hazardous by the OSHA Hazard Communication Standard (29 CFR 1910.1200).
DANGER!
Causes skin and eye burns.
May cause sensitization by inhalation and skin contact.
May cause respiratory tract irritation.
• • •
Avoid contact with eyes, skin and clothing.
Contact with acids liberates toxic gas.
Wear appropriate personal protective equipment (see section 8 for additional information).
Fire and Explosion Hazards: Potential for dust explosion may exist. This product is not defined as
to loose water of crystallization at 122°F (60°C). Depending upon conditions, dust may be sensitive to static
flammable or combustible but may decompose violently if heated above 266°F (130°C). This product will begin
discharge. Avoid possibility of dry powder with friction causing static electricity in presence of flammables.
(See NFPA-77, Chapter 6).
Appearance and odor: White crystalline powder with a weak chlorine odor.
POTENTIAL HEALTH EFFECTS [See Section 11 for additional information]
Primary Route(s) of Exposure: Skin contact, eye contact and inhalation.
However, years of use of Chloramine-T indicates that the risk of allergic skin reaction is limited.
Skin Contact: Considered corrosive to the skin. Contact may cause allergic reaction in sensitive individuals.
Eye Contact: Considered corrosive to the eyes.
Inhalation: Inhalation of dust is irritating to mucous membranes and may cause asthma-like symptoms.
Issue date: 18-Feb-05
MSDS No.: 04 - 041030
Expiry date: 18-Feb-08
Page 1/8

<<<PAGE 6>>>

axcentive
Material Safety Data Sheet
HALAMID®
SECTION 2. HAZARDS IDENTIFICATION (CONTINUED)
Ingestion: Ingestion may cause irritation or burns of the mouth, throat, esophagus and stomach. Ingestion
may cause nausea and vomiting
Carcinogenicity: IARC, NTP, ACGIH or OSHA does not classify this material or its components as a
carcinogen or suspect carcinogen.
Medical conditions aggravated: Persons with pre-existing skin and/or respiratory disease may be at
increased risk if exposed to this material.
This product is not expected to be harmful to aquatic life, based on available data.
POTENTIAL ENVIRONMENTAL EFFECTS [See Section 12 for additional information]
SECTION 3. COMPOSITION / INFORMATION ON INGREDIENTS
INGREDIENTS [See section 8 for exposure limits]
% (w/w)
CAS Number
Benzene sulfonamide, N-Chloro-4-methyl, sodium salt
99.0-100.0
127-65-1/7080-50-41
The anhydrous substance (CAS# 127-65-1) covers all hydrated forms of this product. The trihydrate substance (CAS#
7080-50-4) is the only commercially available and chemically stable form of Sodium p-Toluenesulfonchloramide.
SECTION 4. FIRST AID MEASURES
water for at least 15 minutes. Do not attempt to neutralize with chemical agents. Get medical attention. Wash
Skin Contact: Immediately remove contaminated clothing and shoes. Wash skin with soap and plenty of
contaminated clothing before reuse. Thoroughly clean or destroy contaminated shoes.
Eye Contact: Flush eyes with large quantities of running water for a minimum of 15 minutes. If the victim is
surface of the eye and lids with water. DO NOT let victim rub eye(s). Do not attempt to neutralize with chemical
wearing contact lenses, remove them. Hold the eyelids apart during the flushing to ensure rinsing of the entire
agents. Oils or ointments should not be used at this time. Get medical attention if eye irritation occurs.
Inhalation: Remove victim to fresh air. If respiratory irritation occurs or if breathing is difficult, get medical
attention. If breathing has stopped, give artificial respiration. Maintain airway and administer oxygen if
available. Get medical attention immediately.
Ingestion: DO NOT induce vomiting. If victim is conscious and alert, rinse mouth and give plenty of water to
drink. If vomiting occurs, keep head below hips to reduce risk of aspiration. Give fluids again. Activated
charcoal may be administered (not during vomiting) preferably by a physician [See Note to Physician below].
Never give anything by mouth to a person who is unconscious or convulsing. If victim is unconscious, monitor
pulse, breathing and airway. If breathing stops, begin artificial respiration immediately. If the heart has
stopped, give cardiopulmonary resuscitation (CPR). Get medical attention immediately.
charcoal slurry, suspend 50 g of activated charcoal in 400 ml of water in a plastic bottle and shake well.
Note to Physician: Attending physician should treat exposed patients symptomatically. To prepare activated
Administer 5 mi/kg or 350 mL for an average adult. [A literature reference suggests that Chloramine-T can
react with some amino acids in the gastrointestinal tract to form cyanogen compounds].
Issue date: 18-Feb-05
MSDS No.: 04 - 041030
Expiry date: 18-Feb-08
Page 2/8

<<<PAGE 7>>>

axcentive
Material Safety Data Sheet
HALAMID®
SECTION 5. FIRE FIGHTING MEASURES
Conditions of Flammability:
Flash Point (Method):
not flammable or combustible
Upper Flammable Limit (% by volume):
377.6°F (192°C) [Pensky-Martens Closed Cup]
Auto-Ignition Temperature:
Lower Flammable Limit (% by volume):
not applicable
product decomposes prior to ignition
not applicable
Extinguishing Media: Use water fog or spray, dry chemical, foam or carbon dioxide extinguishing agents.
Fire Fighting Procedures: As in any fire, prevent human exposure to fire, smoke, fumes or products of
contained breathing apparatus and impervious protective clothing. If not leaking, keep fire-exposed containers
combustion. Evacuate all non-essential personnel from the fire area. Fire fighters should wear full-face, self-
cool with a water spray to prevent rupture due to excessive heat.
Fire & Explosion Hazards: Potential for dust explosion may exist. This product is not defined as flammable
or combustible. May decompose violently if heated above 266°F (130°C). This product will begin to loose
water of crystallization at 122°F (60°C). Depending upon conditions, dust may be sensitive to static discharge.
Avoid possibility of dry powder with friction causing static electricity in presence of flammables. (See NFPA-77,
Chapter 6)
distillation of the total water content.
Other Fire & Explosion Hazards: This product has been reported as being explosive after azeotropic
Hazardous Combustion Products: Thermal decomposition products may release toxic and/or hazardous
fumes and gases, including sulfur oxides (SOx), nitrogen oxides (NOx), hydrochloric acid (HCI) and chlorine.
NPFA 704 Hazard Rating - Health:
3
Fire: 1
Instability: 1
Other: None
[0 - Minimal
1 - Slight
2 - Moderate
3 - High
4 - Extreme]
SECTION 6. AccIDenTAL RELEASE MEAsureS
Spill or Leak: Safely stop source of spill. Restrict non-essential personnel from area. All personnel involved in
spill cleanup should avoid skin and eye contact by wearing appropriate personal protective equipment. Do not
breathe dust.
Cleanup: Sweep up spilled solid material, being careful not to create dust. Return sweepings to stock or, if
regulations. Flush remainder with water. Do not allow to escape into sewage system or water courses.
contaminated, place into a chemical waste container for disposal. Dispose of waste according to all
SECTION 7. HANDLING AND STORAGE
Handling: Avoid inhalation of dust and prolonged and/or repeated skin and eye contact.
cool, dry, well-ventilated area away from flammable, reducing or oxidizing materials and sources of heat or
Storage: Store away from foodstuffs or animal feed. Containers should be kept tightly capped and stored in a
flame. Exercise due caution to prevent damage to or leakage from the container.
Maximum Storage Temperature: 140°F (60°C) - Storage at higher temperatures will cause loss of
crystalline structure.
General Comments: Avoid generation of dust when handling this product. Follow good manufacturing and
handling practices.
Issue date: 18-Feb-05
Expiry date: 18-Feb-08
MSDS No.: 04 - 041030
Page 3/8

<<<PAGE 8>>>

axcentive
Material Safety Data Sheet
HALAMID®
SECTION 8. ExposurE CoNTrOL / PERSONAL PROTECTION
Applicable Exposure Limits: In addition to any exposure limits displayed below, exposures to this product
• OSHA - 15 mg/m (total dust) ; 5 mg/m (respirable fraction)
should be controlled below limits established for "Particulates Not Otherwise Classified (PNOC)":
OSHA - PELS
Chemical Name
(mg / m)
ACGIH - TLVs
NIOSH - RELS
(mg / m3)
(mg / m°)
TWA
STEL / CEIL(C)
TWA
STEL / CEIL(C)
TWA
STEL I CEIL(C)
SUPPLIER
sulfonchloramide
Sodium p-Toluene
N/D
N/D
N/D
N/D
N/D
N/D
N/D
[Ref: ACGIH Guide to Occupational Exposure Values, 2004 Edition]
Legend:
STEL: Short Term Exposure Limit
CEIL: Ceiling Exposure Limit
TLV: Threshold Limit Value
PEL: Permissible Exposure Limit
RE Tinene Average Limit.
N/D: Not Determined
Engineering Control - Ventilation: Special ventilation is usually not required under normal use conditions.
Ensure that existing ventilation is sufficient to prevent the circulation and/or accumulation of dust in the air.
Personal Protective Equipment (PPE)
respirator with acid gas, dust, mist and fume filters. When using respirator cartridges or canisters, they must be
Respiratory Protection: If handling operations lead to dusting, wear a NIOSH-approved air-purifying full-face
not occur.
changed frequently (following each use or at the end of the work shift) to assure breakthrough exposure does
Skin Protection: Skin contact with the product should be minimized through the use of suitable protective
clothing, gloves and footwear selected with regard for use condition exposure potential.
Eye Protection: Indirect vented, dust-tight goggles are recommended if dust is generated when handling this
product. Eye wash facility should be readily available.
separate area away from the storage/use location. Eating, drinking and smoking should be prohibited in areas
Other Protection - General Hygiene Considerations: All food and smoking materials should be kept in a
where there is a potential for significant exposure to this material. Before eating, drinking and smoking, hands
and face should be thoroughly washed. Safety showers, with quick opening valves, which stay open, and
eyewash fountains, or other means of washing the eyes with a gentle flow of cool to tepid tap water, should be
readily available in all areas where this material is handled or stored. Water should be supplied through
insulated and heat-traced lines to prevent freeze-up in cold weather. Long sleeved clothing may be used to
minimize skin contact.
SECTION 9. PHYSICAL AND CHEMICAL PROPERTIES
Boiling Point:
Physical State / Appearance / Odor:
not determined
white crystalline powder with a weak chlorine odor
Bulk Density:
~ 590 kg/m°
Cloud Point:
not determined
Evaporation Rate (Butyl Acetate=1):
not determined
Odor Threshold:
Melting Point:
not determined
not determined (decomposes before melting)
pH:
Pour Point:
Partition Coefficient [Octanol-Water]
log Kow = - 1.3
8 - 10.3 (5% solution)
Solubility in water:
not determined
Solubility in other solvents:
150 g/l @ 25°C
75 g/1 @ 20°C in 95% ethanol
Issue date: 18-Feb-05
MSDS No.: 04 - 041030
Expiry date: 18-Feb-08
Page 4/8

<<<PAGE 9>>>

axcentive
Material Safety Data Sheet
HALAMID®
SECTION 9. PHYSICAL AND CHEMICAL PROPERTIES (CONTINUED)
Specific Gravity (HO = 1):
Vapor Density (Air = 1):
1430 kg/m
Vapor Pressure:
not applicable
Viscosity:
not determined
Volatiles (% by weight):
not applicable
not determined
Conditions of Flammability:
not flammable or combustible
Flash Point (Method):
Upper Flammable Limit (% by volume): not applicable
377.6°F (192°C) [Pensky-Martens Closed Cup]
Auto-Ignition Temperature:
Lower Flammable Limit (% by volume): not applicable
product decomposes prior to ignition
<: less than
> : greater than
~: approximately
SECTION 10. STABILITY AND REACTIVITY
Stability: This product is stable under recommended storage and handling conditions (see section 7)
However, it may decompose if exposed to elevated temperatures. It will become unstable in humid conditions.
oxidizers. Contact with acids liberates toxic gas. Avoid prolonged storage at elevated temperatures.
Incompatibilities / Conditions to avoid: This product is incompatible with acids, reducing agents and strong
Polymerization: Hazardous polymerization is not expected to occur under normal temperatures and
pressures.
Hazardous Combustion Products: Thermal decomposition products may release toxic and/or hazardous
fumes and gases, including sulfur oxides (SOx), nitrogen oxides (NOx), hydrochloric acid (HCI) and chlorine.
SECTION 11. TOXICOLOGICAL INFORMATION
INHALATION
Acute exposure: The acute 4 hr. LC50 for this product in rats is greater than 0.275 mg/L (maximum
Chronic exposure: This product may cause asthma-like symptoms based on limited human data.
attainable dust concentration).
SKIN
form of Halamid is corrosive to rabbit skin following a 4 hour exposure period while an 8% solution is not
Acute contact: Dermal toxicity (LD50) is greater than 2,000 mg/kg in rabbits (8% solution). The pure powder
irritating to skin.
Chronic contact: No data available.
EYES: This product is corrosive to rabbit eyes.
INGESTION
Acute exposure: The oral LD50 for this material is approximately 1,000 mg/kg (rat/mice).
Chronic exposure: In a 90 day feeding study, the NOEL (No Observed Effect Level) in albino rats was
approximately 15 mg/kg.
SENSITIZATION: This product was a strong skin sensitizer in the guinea pig maximization test and local
lymph node assay. However, years of use of Chloramine-T indicates that the risk of allergic skin reaction is
Issue date: 18-Feb-05
MSDS No.: 04 - 041030
Expiry date: 18-Feb-08
Page 5/8

<<<PAGE 10>>>

axcentive
Material Safety Data Sheet
HALAMID®
SECTION 11. TOXICOLOGICAL INFORMATION (CONTINUED)
CARCINOGENICITY: IARC, NTP, ACGIH or OSHA does not classify this material or its components as a
carcinogen or suspect carcinogen.
MUTAGENICITY: This product gave negative results in the Ames test, mouse lymphoma forward mutation
assay, DNA repair test, and in vivo mouse micronucleus assay at doses up to 1200 mg/kg.
REPRODUCTIVE TOXICITY / TERATOGENICITY / NEUROTOXICITY: No data are currently available.
OTHER TOXICOLOGICAL EFFECTS: None known
TARGET ORGANS: Skin, eyes and respiratory system.
SECTION 12. ECOLOGICAL INFORMATION
Ecotoxicity: This product is not expected to be harmful to aquatic life, based on the following ecotoxicity data:
Test
Fathead Minnow
Guppies (Poecilia Reticulata)
Exposure / Duration
96-h
LC50 = 31 mg/L
Test Results
Saltwater Brine Shrimp
35 days
72-h
NOEC = 1.1 mg/L (early life stage study)
EC50 = 24.6 mg/L ; NOEC = 10.4 mg/L
Daphnia magna
21 days (chronic
48-h
EC50=> 23 mg/L (flow through conditions)
LC50 = 4.5 mg/L (static conditions)
study).
EsC5o (reduction in growth) = 4.5 mg/L
NOEC = 1.1 mg/L ; LOEC = 3.5 mg/L
Inhibition
Freshwater Algal Growth
96-h
E,C50 (reduction in specific growth rate) = 13 mg/L
NOEC = 0.2 mg/L
LOEC = 0.6 mg/L
Algae (Chlorella pyrenoidosa)
96-h
EC50 = 5 mg/L (Aerobic saprophytic bacteria)
EC50 = 80 mg/L, as PTSA (para-Toluenesulfonamide)
Activated Sludge Bacteria
None specified
EC50 = 1000 mg/L (Methanogenic bacteria)
EC5o = 700 mg/L (Nitrifying bacteria)
Pseudomonas Putida Bacteria
Earthworms (Eisenia fetida)
7 days
None specified
EC10 = 10 ppm (mg/L)
.C50 = 527 mg/kg
speedy biodegradability indicate a low bioaccumulation potential.
Bioaccumulation: The high solubility in water of this product, its low adsorption to soil and sludge and its
Chemical Fate / Biodegradation: This product is readily biodegradable if it is in sufficiently low
toluene sulfonamide that biodegraded 90% in 28 days in the Repetitive Die Away Test.
concentrations in water. The hydrolysis product is also readily biodegradable. This product hydrolyses to p-
SECTION 13. DISPOSAL CONSIDERATIONS
waste by characteristics or listings. It is the responsibility of the waste generator to evaluate whether his
Waste Disposal: in its unused condition, this product is not considered to be a RCRA defined hazardous
wastes are hazardous by characteristic or listing. Dispose in accordance with all local, state and federal
regulations
emptied containers retain product residue, follow label warnings even after container is emptied. Empty
Container Disposal: Containers should be cleaned of residual product before disposal or return. Since
containers should be disposed of or shipped in accordance with all applicable laws and regulations.
Issue date: 18-Feb-05
MSDS No.: 04 - 041030
Expiry date: 18-Feb-08
Page 6/8

<<<PAGE 11>>>

axcentive
Material Safety Data Sheet
HALAMID®
SECTION 14. TRANSPORT INFORMATION
IMDG, ICAO/IATA] as follows:
Shipping Information: This product is regulated for shipping by all modes [per US DOT, Canada TDG,
Corrosive solid, basic, organic, n.o.s. [Sodium p-toluenesulfonchloramide]
2004 Emergency Response Guidebook No.: 154
8, UN3263, PG III
Required Labels: Corrosive
Environmentally Hazardous Substance [per 49 CFR 172.101, Appendix A or B): None
SECTION 15. REGULATORY INFORMATION
The component is subject to the following environmental regulatory lists:
Substance Name
CAA
CERCLA
IARC
US STATE RIGHT:
TO-KNOW LISTS
PROP
65
SARA
Sodium p-Toluene sulfonchloramide
N/R
N/R
N/R
N/R
N/R
N/R
National Chemical Inventories Status:
Substance Name
TSCA
US
DSL
Canada
NDSL
EINECS
EU
Australia®
AICS
Japan
ENCS
Korea
KECL
Philippines
PICCS
China
sulfonchloramide
Sodium p-Toluene-
(see note below)
x
x
x
x
x
x
N/R = Non Regulated
X= Listed
Other Regulatory Information: For inventory reporting purposes, listing of the anhydrous substance [CAS#
127-65-1] covers all hydrated forms of this product. The trihydrate substance (CAS# 7080-50-4) is the only
commercially available and chemically stable form of Sodium p-Toluenesulfonchloramide.
AICS
Legend
CA List
Australian Inventory of Chemical Substances
CERCLA
CAA
Clean Air Act, Section 112
California - Directors List of Hazardous Substances
EINECS
DSL
Domestic Substances List - Canada
FL List
ENCS
European Inventory of Existing Commercial Chemical Substances
Japan Existing and New Chemical Substances
KECL
IARC
International Agency for Research on Cancer - Carcinogens - Groups 1, 2A or 2B
MN List
MA List
Massachusetts - R-T-K Substance List
Korea Existing and Evaluated Chemical Substances
NJ R-T-K
NDSL
Minnesota - Hazardous Substance List
Non-Domestic Substances List - Canada
PA List
New Jersey - R-T-K Hazard List
Prop 65
PICCS
Pennsylvania Hazardous Substance List
Philippines Inventory of Chemicals and Chemical Substances
SARA
RI List
Rhode Island - Hazardous Substance List
TSCA
Toxic Substances Control Act - USA
SARA Title III, Section 302 / 313
WHMIS (Workplace Hazardous Materials Information System - Canada)
• Class D2A, D2B [Other toxic effects]
Class E [Corrosive]
the MSDS contains all the information required by the CPR.
This product has been classified in accordance with the hazard criteria of the Controlled Products Regulations (CPR) and
[0 - Minimal
HMIS Rating - Health: 3
1 - Slight
Flammability: 1
2 - Moderate
3 - High
Reactivity: 1
4 - Extreme
*- Chronic Health Hazard (see Section 11)]
Other: none
Issue date: 18-Feb-05
MSDS No.: 04-041030
Expiry date: 18-Feb-08
Page 718

<<<PAGE 12>>>

axcentive
Material Safety Data Sheet
HALAMID®
SECTION 16. OTHER INFORMATION
Other Information: None available.
Prepared by: ANCI Regulatory Toxicology Dept. [M. Morin - Tel. (613) 273-8095]
formation concerning this product and/or all suggestions for handling and use contained herein are offered in good faith and are believed to be reliable as of th
le information in this Material Safety Data Sheet should be provided to all who will use, handle, store, transport or otherwise be exposed to this product
All
date of publication.
including mixing with other products.
or extending any license under any patent.
document is more than three years old, please call to ensure that this sheet is current.
sue date: 18-Feb-l
niry date: 18-Feh-(
MSDS No.: 04 - 041030
Page 8/8
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