LabelMaster Services — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation 1200 New Jersey Avenue SE Washington. DC 20590 Pipeline and Hazardous Materials Safety Administration JUN 1 0 2015 Mr. Robert Richard Vice President Labelmaster Services 5724 N. Pulaski Road Chicago, IL 60646 Reference No. 15-0081 Dear Mr. Richard: This is in response to your April 23, 2015 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to test methods for corrosion to metals. In your letter, you state it is your understanding that a solid material which is not likely to become liquid during transportation and has a melting point greater than 55°C need not be tested for corrosivity to metals per § 173.137(c)(2). You further state that the solid material is not classified as a Class 8 corrosive substance, unless it causes full thickness destruction of human skin at the site of contact within a specified period of time. You ask whether your understanding is correct. Provided the material meets the definition of a solid in § 171.8, your understanding is correct. The definition of a corrosive material in § 173.136(a) states, "For the purpose of this subchapter, 'corrosive material' (Class 8) means a liquid or solid that causes full thickness destruction of human skin at the site of contact within a specified period of time. A liquid, or a solid which may become liquid during transportation, that has a severe corrosion rate on steel or aluminum based on the criteria in § 173.137(c)(2) is also a corrosive material." While both solids and liquids are subject to the criteria for skin destruction in §173.136(b), only liquids and solids which may become liquid during transportation should be tested in accordance with § 173.137(c)(2). I trust this information is helpful. If you have further questions, please do not hesitate to contact this office. Sincerely, I Hunniester T. Glenn Foster Chief, Regulatory Review and Reinvention Branch Standards and Rulemaking Division#

Page 2Lehman $/73/36 Can 8 LABELMASTER genders SERVICES 15-0081 April 23, 2015 Charles Betts, Director Standards and Rulemaking Division Pipeline and Hazardous Materials Safety Administration Attn: Standards and Rulemaking Division, PHH-10 U.S. Department of Transportation 1200 New Jersey Avenue, S.E. East Building, Floor 2 Washington, DC 20590-0001 Subject: Request for Interpretation; Corrosion to Metals Testing for Solid Materials Dear Mr. Betts: I am writing to confirm my understanding of the requirements for testing solid materials according to §173.136 of the US Hazardous Materials Regulations (HMR) and Section 37.4 of the United Nations Manual of Tests and Criteria for corrosion to metals. The corrosivity to metals test is required to determine if a material meets the criteria for a Class 8, Packing Group III hazardous material. In previous correspondence with Duane Pfund, Director International Standards for the Office of Hazardous Materials Safety, Mr. Pfund agreed with my understanding that only solids that may become liquid during transport need to be tested. Nevertheless, I am requesting confirmation in writing from PHMSA that my understanding is correct and consistent with the HMR, UN Manual of Tests and Criteria and international regulations including the International Maritime Dangerous Goods (IMDG) Code. The UN Manual of Tests and Criteria specifically states: 37.4 Test methods for corrosion to metals 37.4.1 Introduction 37.4.1.1 Test C.1: Test for determining the corrosive properties of liquids and solids that may become liquid during transport as dangerous goods of Class 8, packing group III. The HMR states: §173.136 Class 8-Definitions. (a) For the purpose of this subchapter, "corrosive material" (Class 8) means a liquid or solid that causes full thickness destruction of human skin at the site of contact within a specified period of time. A liquid, or a solid the criteria in § 173.137(c)(2) is also a corrosive material. which may become liquid during transportation, that has a severe corrosion rate on steel or aluminum based on It is my understanding based on the text in paragraph 37.4.1.1 and §173.136 that only solids which may become liquid in transport need be tested. A solid material that has a melting point greater than 55 °C need not be tested for corrosivity to metals and need not be classified as a Class 8 corrosive substance unless it causes full#

Page 3thickness destruction of human skin at the site of contact within a specified period of time since it is not likely of becoming liquid in transport. Please provide confirmation that your office agrees with my understanding and interpretation of the applicable regulations. Respectfully, Rabet A Kil Robert Richard Vice President Labelmaster Services 5724 N. Pulaski Rd Chicago, Illinois 60646#