{"operation":"document","citation":"15-0151","title":"HS&amp;E Coordinator — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2015-10-21","effective_on":null,"summary":"15-0151 response to HS&amp;E Coordinator concerning 171.8, 173.150, 173.22.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-15-0151.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-15-0151.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-15-0151","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2015/150151.pdf","body":"<<<PAGE 1>>>\n\nof Transportation\nU.S. Department\n1200 New Jersey Avenue, SE\nWashington, D.C. 20590\nMaterials Safety\nPipeline and Hazardous\nAdministration\nPeter Leus\nHS&E Coordinator\nOCT 2 1 2015\nRockline Industries\n1113 Maryland Ave.\nSheboygan, WI 53081\nRef. No.: 15-0151\nDear Mr. Leus:\nThis is a response to your July 20, 2015 letter requesting clarification of the Hazardous\nMaterials Regulations (HMR; 49 CFR Parts 171-180) applicable to the classification of an\naqueous solution of alcohol. In your letter, you state that you have an aqueous solution\nwhich consists of four individual components other than water:\nComponent\nCAS Number\nIsopropyl Alcohol\nWt (%)\nAlkyl Dimethyl Benzyl Ammonium Chloride\n67-63-0\nAlkyl Dimethyl Ethyl Benzyl Ammonium Chloride\n68391-01-5\n21.0%\n.154 %\nEthylene Glycol Monobutyl Ether\n68956-79-6\n111-76-2\n.154%\nde minimis\nSpecifically, you ask whether Germicidal Solution® is eligible for the aqueous solutions of\nalcohol exception provided in § 173.150(e)(2) of the HMR in that the material is not subject\nto the requirements of the subchapter if it contains no less than 50 percent water.\nThe exception for aqueous solutions of alcohol, as provided in § 173.150(e) of the HMR, is\nnot applicable when another hazardous material is added to the solution. The term\n\"hazardous material\" is defined in § 171.8 as follows:\n\"a substance or material that the Secretary of Transportation has determined is capable of\nposing an unreasonable risk to health, safety, and property when transported in\ncommerce, and has designated as hazardous under section 5103 of Federal hazardous\nmaterials transportation law (49 U.S.C. 5103). The term includes hazardous substances,\nhazardous wastes, marine pollutants, elevated temperature materials, materials designated\nas hazardous in the Hazardous Materials Table (see 49 CFR 172.101), and materials that\nmeet the defining criteria for hazard classes and divisions in part 173 of this subchapter.\"\nThis Office does not determine if components of a solution are hazardous. Under § 173.22\nof the HMR, this responsibility is placed on the shipper. If a component (i.e., Alkyl\nDimethyl Benzyl Ammonium Chloride, Alkyl Dimethyl Ethyl Benzyl Ammonium Chloride,\nor Ethylene Glycol Monobutyl Ether) is a hazardous material under the HMR, the exception\nin § 173.150(e) does not apply. However, if you can establish that the other components\n1\n\n<<<PAGE 2>>>\n\nthe exception in § 173.150(e).\nused in your solution do not meet the definition of a hazardous material, then it is eligible for\nI hope this information is helpful. If you have any more questions, please do not hesitate to\ncontact this office.\nSincerely,\nTHen Footer\nT. Glenn Foster\nChief, Regulatory Review and Reinvention Branch\nStandards and Rulemaking Division\n2\n\n<<<PAGE 3>>>\n\nMichels\n173.150\nGoodall, Shante CTR (PHMSA)\nExceptions for Class\nFrom:\nGeller, Shelby CTR (PHMSA)\n15 - 0151\nSent:\nTo:\nTuesday, July 21, 2015 3:01 PM\nHazmat Interps\nSubject:\nFW: Interpretation Request\nAttachments:\nDOT Interpretation Request - Germicidal Solution.pdf; Weiman Germicidal Solution\nSDS.PDF; Regulations 173.150 and 173.132.pdf\nDear Shante and Alice,\nPlease see the request for a formal letter of interpretation.\nThanks,\nShelby\nFrom: Peter Leus [mailto:PALeus@ROCKLINEIND.com]\nTo: PHMSA HM InfoCenter\nSent: Monday, July 20, 2015 9:19 PM\nSubject: Interpretation Request\nPlease refer to the attachments.\nThank you for your assistance.\nPeter Leus\nHS&E Coordinator\nRockline Industries\n1113 Maryland Ave.\nSheboygan, WI 53081\nCell: 920-334-0146\nThis email message and any files transmitted with it are intended for the addressee only and may contain information that is confidential.\nUnauthorized use is strictly prohibited and may be unlawful.\ndelivery to the addressee. If you have received this email in error, please notify the sender and delete this email.\nGeneral Statement: If you are not the addressee, you should not read, copy, disclose or otherwise use this message except for the purpose of\nViruses: This email message has been scanned for viruses by Mimecast.\nPlease consider the environment - do you really need to print this email?\n1\n\n<<<PAGE 4>>>\n\nROCHLINE\nINDUSTRIES\nU.S. DOT\nJuly 20, 2015\nPHMSA Office of Hazardous Materials Standards\nAttn: PHH-10\nEast Building\n1200 New Jersey Avenue, SE.\nWashington, DC 20590-0001\nRockline is requesting an interpretation regarding the DOT classification of alcohol water solutions. It is\nour understanding that 49 CFR §173.150(e)(2) excepts solutions of less than 24% alcohol and more than\n50% water from DOT requirements if there are no other hazardous materials in the solution.\nFor your consideration an SDS for a \"Germicidal Solution\" is attached. Also attached are the relevant\nregulations regarding this product. This aqueous solution with greater than 50% water contains\nIsopropyl Alcohol (CAS 67-63-0) at 21.0% which is less than the 24% threshold in §173.150(e). It has a\nflash point of 86 F.\nThe other ingredients are:\n• Alkyl Dimethyl Benzyl Ammonium Chloride (68391-01-5) at 0.154%,\n• Alkyl Dimethyl Ethyl Benzyl Ammonium Chloride (68956-79-6) at 0.154%, and\n• Ethylene Glycol Monobutyl Ether (111-76-2) which is below deminimus concentration.\nBecause each of the individual materials could be considered toxic by either inhalation, oral, or dermal\nexposures Rockline is considering conducting review and if necessary testing outlined in 49 CFR\n§173.132(c)(1) - (c)(4) to demonstrate that the mixed solution does not meet the toxicity criteria defined\nin §173.132(a)and (b). This may include literature review and documentation of inhalation toxicity,\ncalculation of toxicity as outlined in §173.132(c)(3).\ndermal and oral toxicity testing, and if adequate data is readily available for individual components,\nThis inquiry wishes confirmation that if our review and testing show toxicity below the levels stated in\n§173.132(a)and (b) that we would we be able to claim the §173.150(e)(2) exception and not have to\nplacard semi trailers or otherwise label the containers?\nSincerely,\nPlease contact me for any additional information that you may require.\nPeter Leus\nHS&E Coordinator\nRockline Industries\n1113 Maryland Ave.\nSheboygan, WI 53081\nCell: 920-334-0146\n\n<<<PAGE 5>>>\n\nREGULATIONS §173.150\nother\nannoyanca or discomfort to a flight crew member ao as\nsimilar property which could cause extreme\npackagings,\n(1.3 gallons) net capacity sach, packed in strong outer\nto prevent the correct performance of assigned duties;\nthat has a subsidiary hazard of Division 6.1, Packing\n(c) Consumer commodities. Except for a matarial\nof this subchapter for an elevated temperature mata-\n(b) Any material that meets the definition in $171.8\nGroup II, a limited quantity which conforms to the pro-\nmarine pollutant.\nrial, a hazardous substance, a hazardous waste, or a\nvisions of paragraph (b) of this section and is a \"con-\nsubchapter,\ncommodity\"\nand reclassed as ORM-D material. In addition to the\nmay be renamed \"Consumer commodity\"\n$179.141 Class 9-Assigument of packing\nThe packing group of a Claas 9 material is as indi-\ngroup.\nexceptions provided by paragraph (b) of this section,\nshipping paper raquirements of subpart C of part 172\nshipments of ORM-D materials are not subject to the\ncated in Column 5 of the §172.101 Table.\nnition of a hazardous substance, hazardous\nof this subchapter, unless the material meets the defi-\n$178.144 Other Regulated Materials (ORM)-\nDetinitions.\nmarine pollutant, or are offered for transportation and\nrial means a material such as a consumer commodity.\nFor the purpose of this subchapter, ORM-D mate-\ntions provided in §178.166.\ntransported by aircraft, and are eligible for the excep-\nwhich, although otherwise subject to the regulations of\nand distilled spirits as defined in 27 CFR 4.10 and\n(d) Alcoholic beverages. An alcoholic beverage (wine\ntransportation due to its form, quantity and packaging.\nthis subchapter presents a limited hazard during\n5.11) i not subject to the requirements of this subchap-\nIt must be a material for which excaptions are provided\ngory of ORM-D matarial ie listed in the §172.101 Table.\nin the §172.101 Table. Each ORM-D material and cats-\n(1) Contains 24 percent or less alcohol by volume;\nleas, and for transportation on passengar-carrying air-\n(2) Is in an inner packaging of 5 L (1.3 gallons) or\n$178,145 Other\nsignment of packing group.\nRegulated\nMaterials Ag-\nchecked or carry-on baggage; or\ncraft conforms to §175.10(a)17) of this subchapter as\nale.\nPacking groups are not assigned to ORM-Dmateri-\npackaging of 260 L (66 gellons) or less, unless trans-\n(9) Is a Packing Group II alcoholic beverage is a\n$178.150 Exceptions for Class 3 (flammable\ncontaining 24 percent or less alcohol by volume and no\n(B) Aqueous solutions of alcohoL An aqueous solution\n(a) General. Exceptions for hazardous materials\nand combustible liquids).\nother basardane material,-\nshipments in the following paragraphs are permittad\n(2) Is not subiest to the requirements of this sub-\n(1) May be reclassed as a combustible liquid.\nCLASSIFICATON\n& EXCEPTIONG\nous material in the §172.101 Table of this subchapter:\nonly if this section is referenced for the specific hazard-\nchapter if it contains no less than 50 percent water.\nble liquids (Class 3) and combustible liquida\n(b) Limited quantities Limited quantities of flamma-\na flash point at or above 38°C (100°F) that does not\n(E) Combustible liquida (1) A flammable liquid with\ntransportation or transported by aircraft, and the apec-\nexcepted from labeling requirements, unless offered for\nmeet the definition of any other hazard class, may be\nreclassed as a combustible liquid. This provision does\nwhen packaged in combination packagings according to\nifcation packaging requirementa of this subchapter\nnot apply to transportation by vessel or aircraft, except\nwhere other means of transportation is impracticable.\nthis paragraph. For transportation by aircraft,\nto a matarial classed as a combuetible liquid in a non-\n(2) The requirements in this subchaptar do not apply\nments of §179.27 of this subchapter and only hazardous\npackage must also comply with the applicable require-\nbulk packeging unless the combustible liquid is a haz-\nmaterials authorized aboard passenger-carrying air-\nardous substance, a hazardous waste, or a marine pol-\ncion, shipments of limited quantities are not ambient to\ncraft may be transported as a limited quantity. In addi-\nor a combustible liquid that is a hazardous substance a\n(3) A combustible liquid that is in a bulk packaging\nsubpart F (Placarding) of part 172 of this subchapter.\nEach package must conform to the packaging require-\nhazardous waste, or a marine pollutant is not subiect to\nkg (66 pounds) gross weight. The following combination\nments of subpart B of this part and may nơt axceed 80\nthe requirements of this subchapter except those per-\npackagings are authorized:\nhazardous waste manifegig:\n(i) Shipping papers, waybills, switching orders, and\npackagings not over 0.5 I (0.1 gallon) net capacity\n(1) For flammable liquids in Packing Group I, inner\n(it) Display of identification numbers on bulk pack-\n(il) Marking of packages:\neach, packed in strong outer packagings;\npackagings not over 1.0 L (0.3 gallons) net capacity\n(2) For flammable liquids in Packing Group IT, inner\nments of subpart F of part 172 of this subchapter;\n(iv) For bulk packagings only, placarding require-\nDivision 6.1, Packing Group II, in which case the inner\neach, unless the material has a subsidiary hazard of\ning requirementa for transport by vessel, sac §176.340\n(v) Carriage aboard aircraft and vessels (for packag-\ncapacity each, packed in a strong outer packaging.\npackagings may not exceed 100 ml (3.38 ouaces) net\nof this subchapter);\ncombustible liquids, inner packagings not over 5.0 L\n(8) For tammable liquids in Packing Group IT and\nand 171.16 of thia subchapter:\n(vi) Reporting incidents as prescribed by 88171.16\n(vil) Packaging requirements of subpart B of this\n-253-\n\n<<<PAGE 6>>>\n\nREGULATIONS §173.132\nincluding assigment of a generic type and shipping\nbefore being offered for transportation or transported,\napproved, in writing, by the Associate Administrator\n(d) Approvals. (1) An organic parowide must be\ntact for 24 hours with the shaved intact skin avoiding\ndaya in balf of the animals tested. The number of ani-\nabrading) of an albino rabbit, causes death within 14\ndescription, except for-\nresults and be in conformity with good pharmacological\nmals tested must ba sufficient to give statistically valid\ncal name in the Organic Peroxides Table in §173.225(c);\n(i) Am organic perocide which is identified by techni-\npractices. The result is expressed in mg/kg body maas.\ning to §178.225(b); or\n(in A mixture of organic peroxides prepared accord.\nconcentration of vapor, mist, or dust which, adminis-\n(8) LOgo for acute toricity on inhalation means that\nsample under the provisions of §179.225(b).\n(iii) An organic peroxide which may be shipped as a\nmale and female young adult albino rats, causes death\ntered by continuous inhalation for one hour to both\nall relevant data concerning physical state, tempera-\n(2) A person applying for an approval must submit\nmaterial is administered to the animale as a dust or\nwithin 14 days in half of the animals tested. If the\nfor the organic peroxide by the competent authority of\nture controls, and tests results or an approval issued\nmist, more than 90 percent of the particles available for\na foreign government.\ninhalation in the test must have a diameter of 10\nconcentrations could be encountered by a human dur-\nmicrons or less if it is reasonably foreseeable that auch\n(e) Testa. The generic type for an organic peroide\nFigure 20.1(a) (Classification and Flow Chart Scheme\nusing the testing protocol from\ntrusts and me in mam i (parts per million)\ning transport. The result is expressed in mg/l of air for\nand Criteria (TBR, see §171.7 of this subchapter).\nfor Organic Peroxides) from the UN Manual of Tests\nfor vapors. See $173.133(b) for LOso determination for\nmixtures and for limit tests.\n$173.129 Class 5, Division 5.2-Assignment of\nuse of the ICgo for acute toxicity on inhalation of dusts\n(i) When provisions of this subchapter require the\npacking group.\nis not available, the ICso for acute toxicity on inhala-\nand mists based on a one-hour exposure and such data\nGroup II in Column 5 of the §172.101 Table.\nAll Division 5.2 materials are assigned to Packing\nby four and the product substituted for the one-hour\nton based on a four-hour exposure may be mulaplied\n$178.182 Class 6, Division 6.1--Definitions.\nLOgo for acute toxicity on inhalation.\nmaterial (Division 6,1) means a material, other tban\n(a) For the purpose of this subchapter, poisonous\ni use of the LOgo for acute toxicity on inhalation of\n(il) When the provisions of this subchapter require\nafford a hazard to health during transportation, or\na gas, which is known to be so toxic to humans as to\nvapore based on a one-hour exposure and such data is\nbased on a four-hour exposure may be multiplied by\nnot available, the LOgo for acute toxicity on inhalation\nwhich, in the absence of adeguate data on human toxic-\ntwo and the product substituted for the one-hour LOgo\nfor acute toxicity on inhalation.\nCLASSIFICATION\n& EXCEPTIONS\nwithin any one bi the following categories When fested\n(1) Is presumed to be tosic to humans because it falla\npercent of its total mass is likely to be dust in a respira-\n(ili) A solid substance should be tested if at least 10\non laboratory animoan henever possible, animal test\nshould be used):\ndata that has been reported in the chemical literature\nble range, e.g. the aerodynamic diameter of that parti-\nshould be tested if a mist is likely to be generated in a\ncle-fraction is 10 microns or less. A liquid substance\ntoxicity of not more than 500 mogisg or a solid with an\n(a) Oral Toxicity. A liquid with an LDga for acute oral\nleakage of the transport containment. In carrying out\nLiDgo for acute oral toxicity of nol more than 200 mg/kg.\n90% (by mas) of a specimen prepared for inhalation\nthe test both for solid and liquid substances, more than\nacute dermal toxicity of not more than 1000 mg/kg.\n(i) Dermal Toxicity. A material with an ADgo for\ndefined in this paragraph (b)(3)(iii).\ntoxicity tasting must be in the respirable range as\nLOgo for acute toxicity on inhalation of not more than\n(iii) Inhalation Toxicity, (A) A dust or mist with an\ngroups to mortures possessing oral or dermal toxicity\nLa For purposes of clasailyine and assigning packing\nin air at 20°C (68°F) greater than or equal to one-fifth\n(B) A material with a saturated vapor concentration\nnecessary to detarmine the acute 10gg of the mixture.\nhazarder according to the criteria in 9175133(1), it is\nof the LOgo for acute toxicity on inhalation of vapore\none of the following methods may he used to determine\nIf a mixture contains more than one active constituent,\nvapore of not more than 5000 ml./mü\nand with an LOgo for acute toxicity on inhalation of\nthe oral or dermal LDgo of the mixture:\nto tear gas, which causes extreme irritation, especially\n(2) Is an irritating material, with properties similar\ndata on the actual mixture to be transported,\n(1) Obtain reliable acute oral and dermal toxicity\nin confined saces.\nthe formulation according to the most hazardous con-\n(2) If reliable, accurate data is not available, claseify\n(1) LDgo (median lethal dose) for acute oral toxicity\n(b) For the purposes of this subchapter-\nstituent of the mixture as if that constituent wera\nis the statistically derived single dose of a substance\ntration of all active constituents; or\npresent in the same concentration as the total concen-\nthat can be expected to cause death within 14 days in\nthe oral route. The LDso value is expressed in terms of\n60% of young adult albino rats when administered by\nmass of test substance per mass of test animal (mg/sg).\nthe material which, administered by continuous con-\n(2) LDgo for acute dermal toxicity means that dose of\n— 247 -\n\n<<<PAGE 7>>>\n\nProduct Code:\nS5N, S5NQ, S5N55\nMATERIAL SAFETY DATA SHEET\nComply with OSHA'S Hazard Communication Standard, 29 CFR 1910.1200.\nPrinted:\nHMIS RATING:\nPage:\n1 of 2\n6/10/2011\nHEALTH = 1 FLAMMABILITY = 3\nREACTIVITY = 0\nPROTECTION = B\nSECTION 1 - CHEMICAL PRODUCT AND COMPANY IDENTIFICATION\nManufacturer:\nProduct Name:\nGermicidal Solution\n755 Tri-State Parkway\nWeiman Products\n24-Hour Number: 1-800-535-5053\nEmergency Contact:\n847-263-3500\nGurnee, IL 60031\nInternational: 1-352-323-3500\nMSDS Issue Date: 02/10/11\nor contact your regional Poison Control.\nSECTION 2 - COMPOSITION/ INFORMATION ON INGREDIENTS\nComponent\nNumber\nOSHA\nIsopropyl Alcohol\n67-63-0\n21.0\n(optional)\nPEL\nACGIH\n400 ppm\nILV\nOther Limits\nAlkyl Dimethyl Benzyl Ammonium Chloride\n68391-01-5\n0.154\n400 ppm\nRecommended\nAlkyl Dimethyl Ethyl Benzyl Ammonium Chloride\n68956-79-6\n0.154\nN/D\nN/D\nN/D\nEthylene Glycol Monobutyl Ether\n111-76-2\n-\nN/D\nN/D\nN/D\n25 ppm\n25 ppm\nN/D\nN/D\nSECTION 3 - HAZARD IDENTIFICATION\nRoutes of Entry: Eye contact, skin contact, skin absorption, inhalation, ingestion.\nEffects of Acute Exposure:\nInhalation: Prolonged or repeated contact may cause lightheadedness and/or irritation to nose and throat.\nEyes: Contact may cause irritation.\nIngestion: Ingestion can cause gastrointestinal irritation.\nSkin: Prolonged or repeated contact may cause irritation.\nEffects of Chronic Exposure: None known.\nMedical Conditions Generally Aggravated by Exposure: Dermatitis and other pre-existing skin conditions.\nCarcinogenicity:\nNTP: N/A\nIARC Monographs: N/A\nOSHA Regulated: N/A\nSECTION 4 - FIRST AID MEASURES\nInhalation: Move person to fresh air. If person is not breathing, call 911 or an ambulance, then give artificial respiration,\npreferably by mouth-to-mouth, if possible.\nEyes: Rinse with water for at least 15 minutes. Remove contact lenses, if present, after 5 minutes, then continue rinsing\neye. If irritation persists, seek medical attention immediately.\nSkin: Take off contaminated clothing. Rinse skin immediately with plenty of water for 15-20 minutes. If irritation persists,\nseek medical attention.\nIngestion: Rinse mouth and throat with water. Drink a quart of water. Get medical attention immediately.\nFlash Point (Method Used): 86°F TCC\nSECTION 5 - FIRE FIGHTING MEASURES\nFlammable Limits: N/A\nAutoignition Temperature: N/A\nExtinguishing Media: Alcohol foam, carbon dioxide, or dry chemical.\nSpecial Fire Fighting Procedures: Follow NIOSH recommended guidelines for alcohol fires.\nUnusual Fire and Explosion Hazards: Vapors can be heavier than air. Never use torch or other source of flame near\nSECTION 6 - ACCIDENTAL RELEASE MEASURES\nSteps to Be Taken in Case Material is Released or Spilled: Absorb spill with an absorbent material and place in\ncontainer for disposal. Wash the contaminated area with water.\nSECTION 7 - HANDLING AND STORAGE\nPrecautionary Information: Keep out of reach of children\nAvoid breathing of vapors and contact with eyes, skin, or clothing.\nHandling and Storage Conditions: Do not store near heat or open flame. Keep container closed when not in use.\nDocument No.: 051007-6\n\n<<<PAGE 8>>>\n\nProduct Code:\nS5N, S5NQ, S5N55\nMATERIAL SAFETY DATA SHEET\nComply with OSHA'S Hazard Communication Standard, 29 CFR 1910.1200.\nPrinted:\nPage:\n6/10/2011\n2 of2\nSECTION 8 - EXPOSURE CONTROL / PERSONAL PROTECTION\nRespiratory Protection (Specific Type): None.\nVentilation: General ventilation normally adequate.\nProtective Gloves: Latex, rubber, nitrile, or polyethylene.\nEye Protection: Safety glasses.\nWork/Hygienic Practices: None.\nOther Protective Clothing or Equipment: None.\nColor: Colorless\nSECTION 9 - PHYSICAL AND CHEMICAL PROPERTIES\nOdor: Alcohol\nProduct State: Liquid\nMelting Point: N/A\nSpecific Gravity (H2O = 1): 0.96\npH: 7.5\nEvaporation Rate (Butyl Acetate = 1): N/A\nVOC: N/C\nSolubility in Water: Complete\nSECTION 10- STABILITY AND REACTIVITY\nStability: Stable.\nIncompatibility (Materials to Avoid): Strong oxidizing agents.\nHazardous Polymerization: Will not occur.\nHazardous Decomposition or By-products: May include and are not limited to oxides of carbon\nConditions to Avoid: Heat, open flames, sparks.\nSECTION 11- TOXICOLOGICAL INFORMATION\nToxicological Data: N/A\nSECTION 12- ECOLOGICAL INFORMATION\nEnvironmental Data: N/A\nSECTION 13- DISPOSAL CONSIDERATIONS\nWaste Disposal Method: Dispose of in accordance with all applicable local, state, and federal regulations.\nSECTION 14- TRANSPORTATION INFORMATION\nDomestic Ground Transport of Non-Bulk Packages: Aqueous Solution of Alcohol {173.150 (e) (2)}, Ltd. Qty.\nAir and International Shipments: Alcohols, n.o.s., (Isopropanol), 3, UN1987, Pkg. Grp. III\nSECTION 15- REGULATORY INFORMATION\nAll ingredients in this product are listed or are excluded from listing on the US Toxic Substances Act (TSCA) Chemical Substance\nSARA Title III, Section 313 reportable chemicals: Ethylene Glycol Monobutyl Ether.\nSECTION 16 - OTHER INFORMATION\nAdditional Information: Use as directed.\nNote: N/A or N/D as an information entry means the data is not applicable or determined, respectively.\nThis document has been prepared using data from sources considered technically reliable. It does not constitute a warranty, express\nor implied, as to the information contained within. Actual conditions of use, handling, storage, and disposal are beyond manufacturer's\nstate, and federal regulations.\ncontrol. User is responsible to evaluate all available information when using this product for any particular use and to comply with local\nDocument No.: 051007-6","truncated":false,"body_characters":23512}