# Dangerous Goods Department — Hazardous Materials Safety Interpretation

- **operation:** document
- **citation:** 15-0046
- **title:** Dangerous Goods Department — Hazardous Materials Safety Interpretation
- **source type:** guidance
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** guidance
- **official:** true
- **published on:** 2015-06-10
- **effective on:** Not available
- **summary:** 15-0046 response to Dangerous Goods Department concerning 173.22.
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-interpretation-15-0046.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-interpretation-15-0046.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-interpretation-15-0046
- **source url:** https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2015/150046.pdf
**body:**

<<<PAGE 1>>>

of Transportation
U.S. Department
Washington, DC 20590
1200 New Jersey Avenue SE
Pipeline and Hazardous
Administration
Materials Safety
JUN 1 0 2015
Sergio Bustamante M.
CSAV Portacontenedores SPA.
Dangerous Goods Department
Plaza Sotomayor 50
Valparaiso, Chile-
Ref. No. 15-0046
Dear Mr. Bustamante:
This is in response to your January 30, 2015 e-mail requesting clarification on the proper
classification of your customer's shipment of bone charcoal under the Hazardous Materials
Regulations (HMR; 49 CFR Parts 171-180).
In your letter, you state it is your understanding that bone charcoal containing 12% carbon is
a Division 4.2 pyrophoric solid or self-heating substance when offered for transportation.
However, you also provide laboratory test results that indicate your customer's product does
not meet the definition of a Division 4.2 (Spontaneously Combustible Material). In
addition, you provide documentation required by 3.3.1, Special Provision 925, of the
International Maritime Dangerous Goods Code (IMDG Code) that confirms the product is
not a self-heating or pyrophoric solid. You request confirmation that your customer's
product is not subject to the requirements of the HMR.
In accordance with § 173.22 of the HMR, it is the shipper's responsibility to properly
classify a hazardous material. This Office generally does not perform this function.
However, based on the test data and certification you provided, we agree that your
customer's product does not meet the definition of a Division 4.2 material. Therefore, if
your customer's product does not meet any other hazard class as defined in part 173 of the
HMR, and is not a hazardous substance, hazardous waste, or marine pollutant, it is not
subject to the HMR.
I hope this information is helpful. Please contact us if we can be of further assistance.
Sincerely;
Frostar
T. Glenn Foster
Chief, Regulatory Review and Reinvention
Standards and Rulemaking Division

<<<PAGE 2>>>

seven.
5173,32 Shippers Responsebili
5173.124 Deferitions
Dodd, Alice (PHMSA)
15-0046
From:
Sent:
Ciccarone, Michael CTR (PHMSA)
Friday, March 13, 2015 11:37 AM
To:
Hazmat Interps
Subject:
FW: Bone Charcoal - request of letter of interpretation,
Sorry guys, here's another one I'm not seeing in filemaker
-----Original Message--.-
From: Ciccarone, Michael CTR (PHMSA)
Sent: Friday, January 30, 2015 2:10 PM
To: Hazmat Interps
Subject: FW: Bone Charcoal - request of letter of interpretation,
Shante/Alice,
Please submit this for a formal letter of interpretation.
Mr. Bustmante's physical address is:
Plaza Sotomayor 50
Valparaiso
Chile
Thanks,
Mike
----Original Message----
From: sbustamante@csavgroup.com [mailto:sbustamante@csavgroup.coml
Sent: Friday, January 30, 2015 12:34 PM
To: PHMSA HM InfoCenter
Cc: Geller, Shelby CTR (PHMSA); halvarez@csavgroup.com; pilot@csav.com; cherman@csavagency-na.com;
security.global@csavgroup.com
Subject: Bone Charcoal - request of letter of interpretation,
Dears: i called few minutes ago to +1(202) 366-4488 and i spoke with Isaac.
We kindly ask you for a letter of interpretation, we need to know if the DOT as Competent Authority accept the import
of this cargo as harmless and the transport inside the country as harmless based on the documentation and description
of the manufacturing process received from the customer.
Thanks for your cooperation.
Best Regards,
Sergio Bustamante M.
Phone: 56-32-220 3666
1

<<<PAGE 3>>>

•
P Please consider the environment before printing this email.
From:
<shelby.geller.ctr@dot.gov>
To:
<sbustamante@csavgroup.com>,
Date:
30-01-2015 12:11
Subject: RE: Bone Charcoal
Dear Sergio Bustamante M.,
We have received your inquiry about the hazardous materials regulations
(HMR) (49 CFR Parts 171-180).
The HMR prescribes the requirements of the Department of Transportation governing the offering and transportation of
hazardous materials in interstate, intrastate, and foreign commerce by rail car, aircraft, motor vehicle, and vessel. While
we cannot provide an exhaustive list of each applicable requirement, we suggest you review section(s) **173.22 and
173.124(b) for additional information on the shipper's responsibility and the definition of division 4.2 (spontaneously
combustible) materials. The hazardous materials regulations are available at the following URL:
http://phmsa.dot.gov/regulations
If you require additional assistance, you may contact the Hazardous Materials Information Center, which is staffed with
regulatory specialists who can quickly answer your questions by phone, Monday through Friday, 9 AM
- 5 PM EST at +1(202) 366-4488.
Sincerely,
Shelby, Hazardous Materials Specialist
An e-mail response from this office is considered informal guidance.
Formal guidance may be requested in accordance with 49 CFR 105.20.
http://phmsa.dot.gov/hazmat/regs/interps
---- Forwarded by Sergio Bustamante/Chile/CSAV on 30-01-2015 14:15 ----
From:
Sergio Bustamante/Chile/CSAV
To:
phmsa.hm-infocenter@dot.gov,
Cc:
Pilot/Chile/CSAV@CSAV_VAP, Hector Alvarez/Chile/CSAV@CSAV_VAP, Security Global/Chile/CSAV@CSAV_VAP
Date:
30-01-2015 02:06
2

<<<PAGE 4>>>

Subject: Bone Charcoal
Dears:
We belongs to CSAV Portacontenedores SPA (Shipping Company).
We have a customer who wants to carry "Bone Charcoal" from Brazil to USA as non dangerous good. When we detected
this situation we reject the shipment because in our opinion the cargo is dangerous good: UN1361, CARBON, class
The customer says that the cargo is not dangerous good based on:
1) To be considered UN1361 the percentage of carbon must be higher that 88% however in this case the percentage of
carbon is around 12% (this is stated in the MSDS)
2) The shipper provided a document where it reads that the cargo passed the tests for self heating substances.
We consider that the cargo is dangerous good based on:
1) The cargo is declared by the customer as "bone charcoal", "charcoal" is included in the Index of the IMDG Code as
synonym of "carbon". The raw material of this cargo are bones from bovines which passed through process of
carbonization (we have attached the description of manufacturing process received from customer: "Carbonization of
the bones is carried out at a temperature of about 750°C for 8 hours"), therefore the cargo is Carbon from animal origin
which is clearly listed in the IMDG Code as dangerous good. On the other hand in the IMDG Code there is no mention
about the percentage of carbon to be classified as UN1361
2) The documents received regarding the tests for self heating substances are not valid to exempt the cargo from the
condition of dangerous good
because:
- There are no laboratories accredited by the Brazilian Competent Authority to do this test.
- In the document there is no mention about that "the product to be loaded has been correctly sampled by trained staff
from that laboratory and that the sample was correctly tested " as required by the special provision 925 of the IMDG
Code.
We have attached the documentation received from customer.
Please confirm if you agree with our position.
Thanks and Best Regards,
Sergio Bustamante M.
CSAV DG Dept
Phone: 56-32-220 3666
(See attached file: MATERIAL SAFETY DATA SHEET - MSDS - EN.pdf) (See attached file: Operation Process of Bone
Charcoal (1).doc)(See attached
file: CZI E-468 B (1).pdf)
(See attached file: Self ignition test for Shipping (1). pdf)
3

<<<PAGE 5>>>

(See attached file: document2015-01-29-101511.pdf)
P Please consider the environment before printing this email.
SAFETY DATA S... of Bone Char...
MATERIAL
Operation Process
CZI E-468 B
(1).pdf
Self ignition test document2015….
for Shippin...

<<<PAGE 6>>>

OSHER
PADRESA
B.K.A.
Bonechar
ISO 9001
MATERIAL SAFETY DATA SHEET - MSDS
1. PRODUCT IDENTIFICATION AND COMPANY
Trade Name: Natural Bone Charcoal
Synonyms: Bone Char, Animal Bone Char, Bone Black.
Chemical Name: Bone Charcoal•
Chemical Formula: C + [Cao(P04)s(OH)2]
Company Name: Bonechar - Carvão Ativado do Brasil Ltda.
Address: 980 Pioneira Maria Cavalcanti Ruy Street - Maringá/PR - Zip Code: 87065-090
Phone Company: (55) 44-3266-1517
Phax: (55) 44-3266-3673
Phone for Emergencies: (55) 44-3266-2014
E-mail: bonechar@bonechar.com.br
2. COMPOSITION AND INFORMATION OF INGREDIENTS
CAS No.: 8021-99-6
Reference EINECS: 232-421-2
Customs Tariff Number: 3802.9090
Generic Name: Hydroxyapatite (Сapo(P04) (0H)2]
Concentration: C =~12%, Caз(P04)2 = ~88%
Number of ONU: The bone charcoal is not listed in ONU number.
3. Physical and Chemical Properties
Property
Specification
Carbon
9 - 11%
Acid-soluble Ash
< 3%
Ash Insoluble
0,7
Tricalcium Phosphate
70 - 76%
Calcium Carbonate
7 - 9%
Calcium Sulfate
D.1 - 0,2%
8.5 - 9,5
Total Specific Surface Area (BET Nº)
200m/g|
Surface Area of Carbon
Iron
50 m/g|
< 0.3%
Pore Size
7,5 - 60.000 nm
Pore Volume
0.225 cm?/g
1/4

<<<PAGE 7>>>

Moisture
< 5%
Apparent Density
0,60 - 0,70 g/cm3
Aspect
Granules
Odor
Odorless
4. FIRST AID
Inhalation: If a person inhale large amounts of particulate matter, transfer the person to an area of fresh air and ventilated, open
the clothes and if necessary put oxygen mask. Provide medical care.
Prolonged Inhalation: The Bone Charcoal absorbs oxygen from the air in work for long periods indoors where it is stored can cause
respiratory deficiencies. If present disordered breathing, give artificial respiration.
Skin Contact: There is no danger, and should only be washed with soap and water in abundance until its elimination.
Eye Contact: Wash immediately with running water in abundance for at least 20 minutes.
Ingestion: If swallowed in small doses, does not harm health, if swallowed in excess must give great volume of water and induce
vomiting.
5. FIRE FIGHTING MEASURES
Explosion: Avoid generating dust; fine dust dispersed in air in sufficient concentrations, and in the presence of an ignition source is a
potential dust explosion hazard
The bone charcoal does not enter burning (their point of combustion in pure oxygen is above 450 ° C).
Extinguishing Media: Use preferably water under pressure in the form of fog, foam extinguisher, dry chemical or carbon dioxide
Special methods: In case of fire fighting, position yourself with the wind at his back.
Protection of those involved in fire fighting: Stay in dangerous zone only with suitable chemical protection clothing and with an
oxygen mask independent of the ambient air. In order to avoid contact with skin, keep a safe distance.
6. EXTENT OF SPILL OR LEAK
Personal precautions: Eliminate all sources of ignition, heat and sparks.
Environmental precautions: Prevent spilled material reaches waterways and sewers.
Procedure for emergency and alarm systems: In case of fire the fire alarm nearest you.
Neutralization: Not applicable.
Recovery: Collect material in clean and dry packages identified. Using a water jet for cleaning location.
Disposition: Dispose of waste in accordance with current legislation.
7. HANDLING AND STORAGE
HANDLING
Prevention of worker exposure: Use proper personal protective equipment.
Guidelines and precautions for safe handling: For safe handling, use personal protective equipment.
Hygiene measures: Use when needed adequate ventilation. Immediately change contaminated clothing and shoes. Contaminated
clothing should be changed and washed before reuse. Prophylaxis skin. After the end of the work, wash hands and face and also after
handling. It is recommended not to smoke, drink, eat or store food in place and is handling the product.
STORAGE
2/4

<<<PAGE 8>>>

Chemical stability in the long term: Bone Charcoal is not dangerous in storage.
Proper storage conditions: store in rooms where there are no other chemicals products or vapors in the air. Keep plastic bags or
paper always tightly closed.
Storage Incompatibilities: The product should be kept away from strong oxidizers.
Recommended packaging: plastic or paper packages.
To avoid loss of property and contamination, the product should be stored in bags of 25 kg or 50 kg, or super bags of 500 kg to 1000
kg in dry and closed local.
It should not be in direct contact with the ground and stacking up to be twenty bags of height, three super sacks or three pallets
8. EXPOSURE CONTROLS AND PERSONAL PROTECTION
Appropriate personal protective equipment: Handling the activated carbon in normal conditions does not present any risk to
health or satety of persons at the tacility. It is recommended to use equipment as appropriate tor their handling.
Protection Eye / Face: Wear safety goggles to chemicals or wide vision. Contact lenses should not be used when working with
Skin and body: Wear boots, apron or clothing appropriate for the job. Although not a material irritating to the skin, it is
recommended to use gloves scrapes, PVC and / or rubber so as not to dirty their hands.
Respiratory Protection: When handling with bone charcoal is recommended to use half-face mask for particulates. When the
charcoal is wet and stored in tanks, the person may only enter into these tanks with breathing apparatus and mask with air or
oxygen as the activated carbon removes all oxygen from the air indoors.
9. TOXICOLOGICAL INFORMATION
Local Effects:
Eyes: Irritation to be particulate matter.
Lungs: When excessively exposed in an environment with high concentration of dust.
Internal mucous membranes: Gauses dryness, when exposed to high concentrations due to high power adsorbent.
Sensitization: In contact with the eyes causes irritation due to particulate matter, with the skin there are no records of major side
effects, can only dry from dehydration and mucous membranes will absorb and therefore dry.
10. ECOLOGICAL INFORMATION
Potential environmental effects: The activated carbon does not cause damage to the environment and may even be incorporated
into the land of agriculture, because it keeps the soil aerated and retains moisture. This is because coal is the source of calcium and
phosphorus.
Ecotuxicity: No ecological problems are expected when the product is handled and used with due care and attention.
11. DISPOSAL CONSIDERATIONS
Product: On the disposal of the product, you should look for legislation at the municipal, state and federal.
Product residues: In the provision of product residue, must be attentive to the legislation at the municipal, state and federal.
Packaging used: In the provision of used packaging of this product should be alert to the legislation at the municipal, state and
federal.
12. TRANSPORT INFORMATION
3/4

<<<PAGE 9>>>

The Bone charcoal is not classified as hazardous for road, rail, sea and air.
The Bone Charcoal is not listed in the UN number.
The Bone Charcoal is delivered on paper or polypropylene bags containing 25 kg or 50 kg, or in super bags of 500 kg to 1000 kg.
Proper Shipping Name: Bone Charcoal.
13. REGUILATIONS
This information sheet of chemical safety was based on the following standards:
"Products used for treatment of water intended for human consumption - Bone Charcoal."The European Standard BS EN
14456:2004 has the status of a British Standard.
"Praducts used for treatment of water intended for human consumption - Inarganic supporting and filtering materials - Methads of
test. "The European Standard BS EN 12902:2004 has the status of a British Standard.
14. OTHER INFORMATION
The information contained in this MSDS has been compiled from various technical publications taken as true. We do not guarantee
the accuracy of the data. The sole purpose of this document is to be a guide for proper handling of the material. It is the
responsibility of the user determine the suitability of this information for adoption of necessary safety precautions.
4/4

<<<PAGE 10>>>

BONECHAR CARVÃO ATIVADO DO BRASIL LTDA.
Bonechar
Escritório: Rua Pioneira Maria Cavalcanti Ruy 980 - Parque Industrial ||
iSO
900~
CEP: 87065-090 Fone: 55-44-3266-1517 Fax: 55-44-3266-3673
MARINGÁ - PARANÁ - BRASIL
E-mail: bonechar@bonechar.com.br Site: www.bonechar.com.br
B.K.A
PROCESSO DE PRODUÇÃO DO CARVÃO DE OSSO NATURAL / PRODUCTION PROCESS OF
NATURAL BONE CHARCOAL
1. Coleta de matéria-prima (ossos bovinos), provenientes de frigoríficos, abatedouros, açougues
bones) from slaughterhouses, butchers controlled by public health, state and federal inspection services.
controlados pela saúde pública, serviços de inspeção estadual e federal . / Collect raw material (cattle
2. A matéria-prima é transportada para a fábrica unidade Paiçandu (I) em caminhões apropriados. / The raw
3. Na fábrica os caminhões são descarregados na recepção, na plataforma da máquina esmagadora. / In
material is transported to the factory in Paiçandu unit in suitable trucks
the factory the trucks are unloaded, in the overwhelming machine platform
4. Transporte de ossos e descarregamento no pátio para o início do processo de cura- no mínimo 90 dias. /
Transport the raw material and discharge them in the courtyard to the beginning of the cure process -
minimum 90 days.
5. Os ossos são classificados em uma peneira vibratória onde são removidos os ossos moles que não são
usados para carvão. / The bones are classified on a vibrating screen which are removed the soft bones that
are not used for bone charcoal.
6. A moagem dos ossos são feitos
transportados em uma rosca elicoidal. / The grinding of the bones are made through a mill where after
• através de um moinho onde após a moagem os ossos são
grinding the bones are transported in a elicoidal thread.
2nd grinding through elicoidal thread
7. Transportar os ossos secos para 2º moagem através de rosca elicoidal. / Transporting the dry bones to
crushed bones before going to the second mill to remove trace residue.
8. Peneirar os ossos triturados antes de ir para 2º moinho para remoção de restos de resíduo. / Sieve the
ready for feed the kiln.
9. Ossos moídos são armazenados prontos para alimentação dos forno. /The ground bones are stored
bones are transported via a bucket elevator.
10. Alimentação do forno, os ossos são transportados através de um elevador de canecas. / Kiln feed,
box on the Kiln.
11. Os ossos são depositados em uma caixa de metal sobre o forno. / The bones are deposited in a metal
processo intermitente e a cada 1,5 horas são retirados em torno 10 kg de carvão em cada tubo. /
12. A carbonização dos ossos é feita a uma temperatura em torno de 750 C° por 8 horas, isto é, em
Carbonization of the bones is carried out at a temperature of about 750°C for 8 hours, i.e. intermittent
process and the time taken every 1.5 hs to about 10 kg of bone charcoal in each pipe.
13. O carvão semi-acabado é resfriado em uma peneira vibratória para ensaque, onde o mesmo fica no
screen for bagging, where it is in stock to be transported to Maringa (II).
estoque para ser transportado para unidade Maringá (II). / The semi-finished product is cooled in a vibrating
The semi-finished coal is transported to Maringa unit (II) to be processed, i.e. ground.
14. O carvão semi-acabado é transportado para unidade Maringá (II) para ser processado, isto é moído. /
15. O carvão é moído de acordo com a especificação do cliente, em peneira vibratória e ensacado em
is ground according to customer specification, in vibrating screen and bagged in bags of 25 kg or in big bags
sacos de 25 kg ou em big bag de 1000 kg e posto em pallets, prontos para embarque. / The bone charcoal
of 1000 kg and put on pallets ready for shipment.

<<<PAGE 11>>>

ORIGINAL
AGRICIA
COLAE DO AS TE
Од
MINISTE
SVA/MARIN: i
VIGAGRO
REPÚBLICA FEDERATIVA DO BRASIL
MINISTÉRIO DA AGRICULTURA, PECUÁRIA E DO ABASTECIMENTO - MAPA
CERTIFICADO ZOOSSANITÁRIO PARA EXPORTAÇÃO DE CARVÃO DE OSSOS DO
BRASIL PARA OS ESTADOS UNIDOS DA AMÉRICA
ANIMAL HEALTH CERTIFICATE FOR BONE CHAR EXPORTATION FROM BRAZIL
TO UNITED STATES OF AMERICA
ORIGEM / ORIGIN
CERTIFICADO NÚMERO CERTIECATE NIMBERLAJ 2AIG)
origem/ Name and address of tire
Nome e endereço do estabelecimento de
Paiçandu -PR-Brasil
Bonechar-Carvão ativado do Brasil Lida. Estrada para Curizona, lote 6-C-13.
stablishment of oripin
Nome do exportador/ Name of consignee
Bonechat-Carvão ativado do Brasil Lida
consginee
lindereço do exportador! Address of
Rua Pioneira Maria Cavalcanti Rey. 980 Maringá-PR• Brasil
Il. DESTINO / DESTINATION
Nome e endereço do estabelecimento de
establishment of destination
destino! Name and address of the
Pismou Technology, INC. 2925 Waterien Drive. Rochester Itil - M1 - 183049.
Nome do importador/ Name of consignor
Plymouth Technology, INC
consignor
Endereço do importador/ Address of the
2925 Waterview Drive, Rochester Hills - MI - 48309 - USA
II. IDENTIFICAÇÃO E TRANSPORTE / IDENTIFICATIONAND TRANSPORTATION
Quantidade : Quantir
Meio de transporte/ Means of transportation
Identificação/ Identfication
Tamina 005N
Maritimo
IV. INFORMAÇÕES SANITÁRIAS / SANITARY INFORMATION:
Eu, abaixo assinado, Veterinário Oficial, certifico que:
I. the undersigned Official Veterinarian. certify that:
1. O carvão de osso foi derivado de bovinos: The hone char wus derived from bovine. '
2.
Durante o processamento o carvão de osso foi aquecido a uma temperatura minima de 800 graus C/
During processing the hone char was heated to a minimum of $00 degrees C
Local / Place: meningé - PR-Man bara: Date: 06C1. 2015
Veterinário Oficial/ Official Veterinarian
Nome/Name: Janismer Pous Cit go
Carimbo e Assinatura do Veterinário Oficial Stamp and Signature of Official Teterinarian
FRANCISHA
•ERES ORTEGA
S00: C21

<<<PAGE 12>>>

MTD
MINTON, TREHARNE
& DAVIES LIMITED
Consulting Scientists, Mariners " Sagineers
Analytical & Testing Laborafories
Our ref: PS/ajr
Public Auntys/s
Certificate No: R13- 08585
24# June 2013
heating. The sample was received from 18th June 2013 and tested as detailed below. Sample identified as:-
We hereby certify that we have analysed the undermentioned sample of Material for propensity towards self
JERET W2060
PRODUCT
Test Method:
Transport of Dangerous Goods
United Nations Recommendations on the
Section 33.3 Division 4.2
Manual of Tests and Criteria - Sth revised edition
Date of testing
21.6.2013
Section 33.3 1.3.1 Pyrophoric Solids
The Sample failed to ignite in air within 5 minutes
Section 33.3 1.3.3. Self heating substances
temperature monitored for 24 hours.
The sample was heated in air at 140°C in a 100mm test cube and its
The sample temperature did not exceed 200°C.
Conclusion:
The sample is not a pyrophoric solid of Division 42.
The sample is not a self heating substance of Division 4.2.
MINTON, TREHARNE & DAVIES LTD
Allomon
J. Robinson
BSc, MSc, MChemA, CSci, CChem, FRSC, MAPA, MIFST
Jeret Ltd
For the attention of: Jerry Elvin
4 Birchgrove,
Houston
Pentrewshire
PA6 7DF
Ene: Neill Clerk & Murray cover letter & UPS Consignment Note:
HEAD OFFICE
MERTON HOUSE, CROESCADARN CLOSt; CARDIFF CF23 8HF UK
ALSO OFFICES AT LONDON, HOUSTON, SINGAPORE, CARMARTHEN
TEL +44(0)2920540000 FAX EAX (0)29 20540111
EMAIL.
mtd@minton.co.uk
WEBSITE:
www.minton.co.uk
REGISTRATION NUMBER: ENGLAND 435262

<<<PAGE 13>>>

DGR
Page 16 of 40
test report, are given in the current edition of the UN Manual of Tests and Criteria, Part II. The statement of approval
Dangerous Goods. The applicable classification procedures, test methods and criteria, and an example of a suitable
must contain the classification and the relevant transport conditions.
3.4.1.2.5 Transport of Samples
Samples of self-reactive substances not listed in Appendix C.1, for which a complete set of test results is not
avalas for d which are us traces type pruthed se following contions are assigned to one of the appropriate
(a) the available data indicate that the sample would be no more dangerous than self-reactive substances type B:
the available data indicate that the control temperature, if any, is sufficiently low to prevent any dangerous
decomposition and sufficiently high to prevent any dangerous phase separation.
3.4.1.2.6 Temperature Control Requirements
self-reactive substances, which require temperature control during transport are forbidden for transport by air unless
With the exception of self-reactive solids of type B which are forbidden for transport by air under any circumstance,
exempted (see 2.1.2). Self-reactive substances must be subject to temperature control if their self-accelerating
3.4.1.2.7 Desensitization of Self-reactive Substances
iluent. When a diluent is used, the self-reactive substance must be tested with the diluent present in the
4.1.2.7.1 In order to ensure safety in transport, self-reactive substances may be desensitized by the use of:
concentration and form to be used in transport.
leakage from the package must not be used.
3.4.1.2.7.2 Diluents which may allow a self-reactive substance to concentrate to a dangerous extent in the event of
those solids or liquids which have no detrimental influence on the thermal stability and hazard type of the self-
3.4.1.2.7.3 The diluent must be compatible with the self-reactive substance. In this regard, compatible diluents are
reactive substance.
be protected from direct sunlight and all sources of heat and be placed in adequately ventilated areas.
During the course of transport, packages or unit load devices containing self-reactive substances of Division 4.1 must
3.4.1.3 Solid Desensitized Explosives
3.4.1.3.1 Solid desensitized explosives are explosive substances which are wetted with water or alcohols or are
Subsection 4.2-List of Dangerous Goods for solid desensitized explosives are UN 1310, 1320, 1321, 1322, 1336,
diluted with other substances to form a homogeneous solid mixture to suppress their explosive properties. Entries in
3344, 3364, 3365, 3366, 3367, 3368, 3369, 3370, 3376, 3380 and 3474.
1337, 1344, 1347, 1348, 1349, 1354, 1355, 1356, 1357, 1517, 1571, 2555, 2556, 2557, 2852, 2907, 3317, 3319,
3.4.1.3.2 Substances that:
(a) Saves een provisionally accepted into Class 1 according to Test Series 1 and 2 but exempted from Test
(b) are not self-reactive substances of Division 4.1;
(c) are not substances of Class 5:
are also assigned to Division 4.1. UN 2956, UN 3241, UN 3242 and UN 3251 are such entries.
3.4.2 Division 4.2-Substances Liable to Spontaneous Combustion
3.4.2.1 Definition
under normal conditions encountered in transport, or to heating up in contact with air, and being then liable to catch
Division 4.2—Substances liable to spontaneous combustion. Substances, which are liable to spontaneous heating
about:blank
23/01/2015

<<<PAGE 14>>>

DGR
Page 17 of 40
fire.
The following types of substances are classified in Division 4.2:
• pyrophoric substances; and
• self-heating substances.
3.4.2.2 Properties
generates heat. If the rate of heat production exceeds the rate of heat loss, then the temperature of the substance
Selt-heating of a substance is a process where the gradual reaction of that substance with oxygen (in the air)
will rise which, after an induction time, may lead to self-ignition and combustion. Two types of substances can be
distinguished with spontaneous combustion properties.
3.4.2.2.1 Pyrophoric Substances
quantities, ignite within 5 minutes of coming in contact with air. These substances are the most liable to spontaneous
Pyrophoric substances (liquid or solid) including mixtures and solutions are substances which, even in small
combustion.
3.4.2.2.2 Self-heating Substances
Self-heating substances are substances, which in contact with air without an additional energy supply are liable to
self-heating. These substances will ignite only in large amounts (kilograms) and after long periods of time (hours or
days).
3.4.2.3 Classification
3.4.2.3.1 Pyrophoric Solids
ith the test methods and criteria of in the current edition of the UN Manual of Tests and Criteria, Part Ill, subsectio
olids are considered pyrophoric solids which must be classified in Division 4.2 if, in tests performed in accordanc
33.3.1, the sample ignites in one of the tests.
lAUDO
3.4.2.3.2 Pyrophoric Liquids
with the test methods and criteria of the current edition of the UN Manual of Tests and Criteria, Part III, subsection
Liquids are considered pyrophoric liquids which must be classified in Division 4.2 if, in tests performed in accordance
33.3.1, the liquid ignites in the first part of the test, or if it ignites or chars the filter paper.
3.4.2.3.3 Self-heating Substances
3.4.2.3.3.1 A substance must be classified as a self-heating substance of Division 4.2 if, in tests performed ir
subsection 33.3.1:
accordance with the test method and criteria in the current edition of the UN Manual of Tests and Criteria, Part I!!
(a)
a positive result is obtained in a test using a 25mm sample cube at 140°C;
(b)
a positive result is obtained in a test using a 100mm sample cube at 140°C and a negative result is obtained in
of more than 3 m°:
a test using a 100mm cube sample at 120°C and the substance is to be transported in packages with a volume
(0) a positiven a m m cued sampit at g° and the subslance t0 0 c apored in pace rages it a voidine
of more than 450 L; and
1) a test sing a 15 medie sample it 1000 mm sample cube at 140°C and a posive resul is oblained in
312d must not Be classied in Dis, on 4-2 but ty Division 4.1 (so 34 21ive resul according to this test
3.4.2.3.3.3 A substance must not be classified in Division 4.2 if:
(a) a negative result is obtained in the test using a 100mm sample cube at at.140°C;
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Page 18 of 40
(c) a positive result is obtained in the test using a 100mm sample cube at 140°C and a negative result is obtained
in the test using a 25 mm cube sample at 140°C, a negative result is obtained in the test using a 100mm cube
sample at 100°C and the substance is to be transported in packagings with a volume not more than 450 L
3.4.2.4 Packing Group Criteria
3.4.2.4.1 Pyrophoric Substances
Pyrophoric liquids and solids of Division 4.2 must be assigned to Packing Group I.
3.4.2.4.2 Self-heating Substances
Self-heating substances must be allocated to packing groups in accordance with the following criteria:
3.4.2.4.2.1 Packing Group I|
140°C.
Packing Group I! must be assigned if the substance gives a positive result in the test using a 25mm cube sample at
3.4.2.4.2.2 Packing Group II!
Packing Group III must be assigned to the substance if:
(a) a positive result is obtained in the test using a 100mm sample cube at 140°C and a negative result is obtained
volume of more than 3 m*;
in the test using a 25 mm cube sample at 140°C and the substance is to be transported in packagings with a
(b)
a positive result is obtained in a test using a 100mm sample cube at 140°C and a negative result is obtained in
he test using a 25 mm cube sample at 140°C, a positive result is obtained in the test using a 100mm cub
ample at 120°C and the substance is to be transported in packagings with a volume of more than 450 L; c
c) a positive result is obtained in the test using a 100 mm sample cube at 140°C and a negative result is obtainer
sample at 100°C.
n the test using a 25 mm cube sample at 140°C and a positive result is obtained in a test using a 100 mm cubi
3.4.3 Division 4.3—Substances Which, in Contact with Water, Emit Flammable Gases
3.4.3.1 Definition
which, by interaction with water, are liable to become spontaneously flammable or to give off flammable gases in
Division 4.3-Substances, which, in contact with water, emit flammable gases (Dangerous when wet). Substances
dangerous quantities.
emits flammable gas.
Where the term "Water-reactive" is used in these Regulations, it refers to a substance, which in contact with water
3.4.3.2 Properties
Certain substances in contact with water, emit flammable gases which can form explosive mixtures with air. Such
unprotected gil is the restored is ae and Tames may endanger people and the environmen. The test.
3.4.3.3 Classification
Suborned is aco dance lace wie meted an antena in the mut be on of ile anua rests and Crieria.
Part Ill, subsection 33.4.1:
(a) spontaneous ignition takes place in any step of the test procedure; or
(b) there is an evolution of a flammable gas at a rate greater than 1 L/kg of the substance per hour.
3.4.3.3.1 Principle of the Method
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<<<PAGE 16>>>

(NTD)
MINTON, TREHARNE
& DAVIES LIMITED
Inayared: desting laboratories
Our ref: PS/ajr
Certificate No: R13- 08585
24" June 2013
heating. The sample was received from 18 June 2013 and tested as detailed below, Sample identified as:-
We hereby certify that we have analysed the undermentioned sample of Material for propensity towards solf
JERET W2060
PRODUCT
Test Method:
Transport of Dangerous Goods
United Nations Recommendations on the
Section 33.3 Division 4.2
Manual of Tests and Criteria - Sth revised edition
Date of testing
21.6.2013
Section 33.3 1.3.1 Pyrophoric Solids
The Sample failed to ignite in air within 5 minutes
Section 33.3 1.3.3. Self heating substances
temperature monitored for 24 hours.
The sample was heated in air at 140°C in a 100mm test cube and its
The sample temperature did not exceed 200°C.
Conclusion:
The sample is not a pyrophoric solid of Division 4.2.
The sample is not a self heating substance of Division 4.2.
MINTON, TREHARNE & DAVIES LTI
MAlloman
BSc, MSc, MChemA, CSci, CChem, FRSC, MAPA, MIFST
J. Robinson
Jeret Lid
For the attention of: Jerry Elvin
Ilouston
4 Birchgrove,
Pentrewshire
PAG 7DF
Ene: Neill Clerk & Murray cover letter & UPS Consignment Note:
HEAl OFFICE
ALSO OFFICES AT LONDON, HOUSTON, SINGAPORE, CAKMAKTHEN
MERTON HOUSE, CROESCAUARN CIOS, CAKE C123 SHE UK
TEL 1++ (0)29205-10000 Eat +41(0)29 20540111
intd@minton.co.uk
WEBSITE www.winton.co.nk
REGISTRATION ATMASK: FRGLAND 195262

<<<PAGE 17>>>

MINTON, TREHARNE & DAVIES LTD.
CONSULTING SCIENTISTS & ENGINEERS
ANALYTICAL & TESTING LABORATORIES
Telephone:
Head Olice
Rapiscratica No.: England 495262
fax:
(91222)5-003
Head Office and Laborzaries
Alter Hours:
Tel4x:
7103 MINTON
01227) 5401
MERTON HOUSE,
CROESCADARN CLOSE,
PENTWYN,
COPIES TE
CARDIFF, CF2 7HE.
N. MCMILLAN
C. DAVIDSON!
J.R. ELVIN
Certificale/Coal No. C3178:001/96
Our ref CRM/AJD
J. RusSEL
6 August 1996
We hereby certify that we have analysed the undermentioned sample in accordance with the
seit-heating test for Charcoal as specified by IMO Code of Safe Practice for Solid Bulk Cargoes
Augus: 199. Sample identific ed
The sample was received by us via Tate & Lyie Process Technology on the 2nc
-
"8 X 24 BONE CHARCOAL"
Test Method
The test sample was heated at 140°C for 12 hours in a 100mm side stainless steel mesh
..man so.,
cage and its temperature monitored.
- :
Test Results
The sample did not undergo spontaneous ignition during the lest period.
The temperature of the sample did not reach 200°C during the rest period.
Cote The temperature indicated by the thermocouple in the middle of the sample indicated
maximum temperature of 142°
MINTON, TREHARNE & DAVIES LTD
C.R. Mullins
lor the attention of Mr A. Newto
faersk Line UT
1 Canada Square
London
Canary Wharf
E14 5DP
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