# Amazing Products Inc. — Hazardous Materials Safety Interpretation - **operation:** document - **citation:** 15-0169 - **title:** Amazing Products Inc. — Hazardous Materials Safety Interpretation - **source type:** guidance - **agency:** Pipeline and Hazardous Materials Safety Administration - **status:** guidance - **official:** true - **published on:** 2016-01-08 - **effective on:** Not available - **summary:** 15-0169 response to Amazing Products Inc. concerning 172.101, 173.22. - **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-interpretation-15-0169.json - **markdown:** https://regulus.evalyn.ai/document/phmsa-interpretation-15-0169.md - **app url:** https://regulus.evalyn.ai/document/phmsa-interpretation-15-0169 - **source url:** https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2016/150169.pdf **body:** <<>> U.S. Department of Transportation 1200 New Jersey Avenue SE Washington. DC 20590 Materials Safety Pipeline and Hazardous Administration JAN 0 8 2016 Ms. Jackie Skaggs Shipping Department Amazing Products, Inc. 6214 Strawberry Lane P.O. Box 14226 Louisville, KY 40214 Ref. No.: 15-0169 Dear Ms. Skaggs: This is in response to your letter dated July 13, 2015 requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) relating to the hazard classification of a solution containing 98-99% sulfuric acid (93% grade) and 1% Rodine. Specifically you ask whether this product is a Packing Group I or Packing Group II material. In accordance with § 173.22, it is the shipper's responsibility to properly classify a hazardous material. This Office does not generally perform that function. While the safety data sheet indicates the solution is a Packing Group II material, it does not provide an indication on how that determination was made. Based only on the information you provided in your letter and the accompanying safety data sheet, this material is composed of a single predominant hazardous material that is identified in the hazardous materials table (Sulfuric acid) and another material (Rodine 85). Provided the presence of Rodine 85 does not impact the hazard class or packing group of the predominant hazardous material the material must be described using the proper shipping name of the hazardous material and the qualifying word "mixture" or "solution." When applied to this case, the shipping description for this material must be UN1830, Sulfuric acid, solution, 8, PG II. If the presence of Rodine 85 changes the hazard class or packing group from the specifically identified material, or significantly changes the measures to be taken in emergencies, or if the material can be appropriately described by a shipping name that describes its intended <<>> application, then a suitable generic or n.o.s. description must be selected and an assigned an appropriate packing group based on the properties of the solution e.g. corrosive liquids, n.o.s. or compounds, cleaning liquid. See § 172.101(c)(10). If you have further questions, please do not hesitate to contact this office. Sincerely, Pan A TAl Duane A. Pfund International Standards Coordinator Standards and Rulemaking Division <<>> Leary Amazing! 5172.101 Amazing Products, Inc. LIQUID HMT FIRE 15-0169 6214 Strawberry Lane P.O. Box 14226 A product of Amazing! Products Louisville, Kentucky 40214 (502) 361-3655 Fax (502) 361-1810 July 13, 2015 Mr. Charles E. Betts Director, Standards and Rulemaking Division U.S. DOT/PHMSA (PHH-10) 1200 New Jersey Ave, SE East Building, 2nd Floor Washington, DC 20590 Mr. Betts, This letter is a request for a Letter of Interpretation on ground shipment classification for a hazardous product. The current shipping description being used for our product, Liquid Fire Drain Opener is UN1760, Corrosive Liquid, N.O.S. (Sulfuric Acid), 8, PGIl. The content of the product is sulfuric acid (93% grade) with content 98 - 99% with 1% Rodine. According to the 49 CFR Part 172.101 Hazardous Materials Table, sulfuric acid with more than 51% is listed as a PG I| material. We have been advised by an FAA employee that our description is not correct, that it should read PG I, not Il. Our previous MSDS and current SDS are enclosed. We await your response. Jackie Skaggs Shipping Department Enclosures Never Mix Drain Pipe Cleaners <<>> 09/2009 MATERIAL SAFETY DATA SHEET "LIQUID FIRE" DRAIN LINE OPENER - MANUFACTURER'S NAME: P.O. BOX 14226 AMAZING PRODUCTS, INC. PHONE: 502-361-3655 LOUISVILLE, KY 40214 E-MAIL: amazingp2@gmail.com 502-361-1810 BUSINESS HOURS: 8:00AM TO 4:30PM EST Monday thru Friday EMERGENCY TELEPHONE NUMBER: INFOTRAC 1-800-535-5053 HAZARDOUS INGREDIENTS/IDENTITY INFORMATION HAZARDOUS COMPONENTS CAS# OSHA PEL ACGIH TLV OTHER LIMITS Rodine 85 Sulfuric Acid 105-55-5 1 mg/m3 7664-93-91 mg/m3 1mg/m3 1mg/m3 NONE NONE PHYSICAL/CHEMICAL CHARACTERISTICS: BOILING POINT: Sulfuric Acid - 535 oF Rodine 85 - 212 oF SPECIFIC GRAVITY (H2O=1):-1.835 VAPOR PRESSURE: VAPOR DENSITY: (mm Hg) : N/A 1.13 - 1.15 (AIR=1) 3.38 MELTING POINT: N/A (Butyl Acetate = 1) EVAPORATION RATE: Less than one APPEARANCE AND ODOR: SOLUBILITY IN WATER: Completely Miscible Dark Amber Liquid with slight pungent odor <<>> FIRE AND EXPLOSION HAZARD DATA: FLASH POINT: Not Flammable: may ignite combustible materials FLAMMABLE LIMITS: N/A LEL: N/A UEL: N/A EXTINGUISHING MEDIA: Use dry chemical or CO2 base fire extinguishers to fight surrounding fire. SPECIAL FIRE FIGHTING PROCEDURES: farthest possible distance. Do not use water on acid itself. Apply from USUAL FIRE & EXPLOSION HAZARDS: Hydrogen Gas on contact with most metals, will react Violent reaction with water. Evolution of explosive with organic material with evolution of heat and dense white fumes. FIRE FIGHTING/PERSONAL PROTECTION: Wear self-contained breathing apparatus and full protective clothing HAZARDOUS REACTIVITY DATA STABILITY: Stable CONDITIONS TO AVOID: DO NOT USE WITH, BEFORE OR AFTER OTHER DRAIN LINE OPENERS OR CHEMICALS- PRIOR KNOWLEDGE OF DRAIN PIPE CONTENTS CRITICAL!! INCOMPATIBILITY: Material is stable when properly handled. Highly reactive with materials such as Metal Oxides, Hydroxides, Nitrates, Amines, Carbonates and a great deal of heat as does the dilution of acid other alkaline materials. Reactions can generate oxidizing agent. May cause ignition of with water. Concentrated acid is a strong generation of Sulfur Dioxide fumes. combustible materials on contact with Avoid open flames or sparks. POLYMERIZATION: DOES NOT OCCUR. HAZARDOUS DECOMPOSITION: Explosive hydrogen gas is generated by the action of acid on most metals. <<>> HEALTH HAZARD DATA ROUTES OF ENTRY: Inhalation, ingestion, direct contact HEALTH HAZARDS: Chronic (delayed) health hazard, and Acute (immediate) health hazard. CARCINOGENICITY: N/A NTP: N/A IARC MONOGRAPH: N/A OSHA REGULATED: YES SIGN AND SYMPTOMS OF EXPOSURE: Severe eye and resp latros, intammation to mucous EMERGENCY AND FIRST AID PROCEDURE EYES: Flush immediately with water for at least 15 minutes. Forcibly hold eyelids apart to ensure complete GET IMMEDIATE MEDICAL ATTENTION. irrigation of eye/lid tissue. SKIN: Wipe off excess. Flush immediately with water for at least 15 minutes while removing contaminated clothing. INGESTION: induce vomiting. Drink copious amounts of water or milk. Do not GET IMMEDIATE MEDICAL ATTENTION. EFFECTS OF OVER EXPOSURE/MEDICAL CONDITIONS AGGRAVATED: Contact with liquid, mist or vapor can cause immediate irritation or corrosive burns to all human tissue. Severity of burn is generally determined by the duration of exposure. Contact with eyes may result in thorough irrigation with water. Swallowing may be permanent visual loss unless removed quickly by damage respiratory tract. Repeated skin contact with fatal. Inhalation of concentrated vapor or mist may dilute solutions may cause dermatitis. May cause dental erosion. <<>> PRECAUTIONS FOR SAFE HANDLING AND USE SPILL OR LEAK CONTROL: Utilize full protective clothing, including boots and protective equipment. Contain spill in order to prevent contamination of sewage system or waterway. Pump into marked containers for reclamation or water in accordance with applicable regulations. disposal. If possible neutralize on a dry basis with WASTE DISPOSAL METHOD: Dispose of spilled, neutralized, or waste product, contaminated soil and other materials in accordance with all local, state and federal regulations. STORAGE AND HANDLING PRECAUTIONS: Store in cool, dry, well ventilated place. Store away from all other chemicals and potential sources of Keep container tightly closed when not in use Wash thoroughly after handling. Do not use pressure to empty container OTHER PRECAUTIONS: DO NOT USE BEFORE, AFTER OR WITH ANY OTHER DRAIN LINE OPENER OR CHEMICAL. AUTHORIZED USER. KEEP AWAY FROM CHILDREN, SPECIFY CONTROL MEASURES RESPIRATORY PROTECTION: In adequate ventilation area use self-contained breathing apparatus. VENTILATION: Windows - Fans PROTECTIVE GLOVES: Rubber EYE PROTECTION: Faceshield and/or Safety Glasses OTHER PROTECTIVE CLOTHING OR EQUIPMENT: (acid resistant hood and full body suit Rubber footwear and protective clothing recommended). WORK/HYGIENIC PRACTICES: Safety Shower - No contact lenses - Eyewash fountains *****IMPORTANT***** This information is based on available scientific evidence known to Amazing Products, Inc. Hazard and Communication Standard. It is solely for compliance with OSHA's This information is furnished without warranty, expressed or implied. <<>> Safety Data Sheet Issue Date: 01-May-2014 Revision Date: 07-Aug-2014 Version 1. IDENTIFICATION Product Name Product Identifier Liquid Fire Drain Line Opener SDS # Other means of identification API-001 UN/ID No UN1760 Recommended Use Recommended use of the chemical and restrictions on use For clogged drains only: Supplier Address Details of the supplier of the safety data sheet Amazing Products, Inc. Louisville, KY 40214 P.O. Box 14226 Company Phone Number Emergency Telephone Number Fax: 502-361-1810 Phone: 502-361-3655 Emergency Telephone (24 hr) INFOTRAC 1-352-323-3500 (International) E-mail: amazingp2@gmail.com 1-800-535-5053 (North America) 2. HAZARDS IDENTIFICATION Appearance Amber liquid Physical State Liquid Odor Slight pungent odor Classification Skin corrosion/irritation Acute toxicity - Inhalation (Dusts/Mists) Category 4 Serious eye damage/eye irritation Category 1 Category 1 Sub-category B May be harmful if swallowe lazards Not Otherwise Classified (HNOC Danger Signal Word Causes severe skin burns and eye damage Hazard Statements Harmful if inhaled Page 1/8 <<>> API-001 - Liquid Fire Drain Line Opener Revision Date: 07-Aug-2014 Use personal protective equipment as required Precautionary Statements - Prevention Use only outdoors or in a well-ventilated area Do not breathe dust/fume/gas/mist/vapors/spray Wash face, hands and any exposed skin thoroughly after handling Wear respiratory protection Precautionary Statements - Response IF IN EYES: Rinse cautiously with water for several minutes. Remove contact lenses, if present and easy to do. Continue rinsing IF ON SKIN (or hair): Remove/Take off immediately all contaminated clothing. Rinse skin with water/shower Immediately call a poison center or doctor/physician IF INHALED: Remove victim to fresh air and keep at rest in a position comfortable for breathing Wash contaminated clothing before reuse IF SWALLOWED: Rinse mouth. Do NOT induce vomiting Call a poison center or doctor/physician if you feel unwell Store locked up Precautionary Statements - Storage Store in a well-ventilated place. Keep container tightly closed Precautionary Statements - Disposal Dispose of contents/container to an approved waste disposal plant 3. COMPOSITION/INFORMATION ON INGREDIENTS Chemical Name Sulfuric Acid 7664-93-9 CAS NO Weight-% 90-100 **If Chemical Name/CAS No is "proprietary" and/or Weight-% is listed as a range, the specific chemical identity and/or percentage of composition has been withheld as a trade secret.** 4. FIRST-AID MEASURES First Aid Measures General Advice personnel aware of the material/s involved and to take precautions to protect themselves In the event of accidental contact, inhalation or ingestion call 911 and make medical while treating affected patient/s. Eye Contact no evidence of the chemical remains (15-20 minutes minimum). Remove contact lenses, if Irrigate with copious amounts of water. Occasionally lift the upper and lower eyelids unto present and easy to do. continue rinsing. Call a physician or poison center immediately. Continue rinsing with tepid water until medical attention is obtained. Skin Contact Remove contaminated clothing and irrigate skin with copious amounts of water. Wipe off crevices, creases, groin). While the patient is transported to a medical facility, continue the excess product. Rinse skin with water/shower for 15 minutes (pay close attention to: Folds, application of cold, wet compresses. Note to physicians: If medical treatment must be delayed, repeat the flushing with tepid water or soak the affected area with tepid water to Inhalation Remove from exposure. If breathing is difficult, remove to fresh air and keep at rest in a Page 2/8 <<>> • API-001 - Liquid Fire Drain Line Opener Revision Date: 07-Aug-2014 Ingestion Rinse mouth, administer small amounts of water or milk if the patient is not in respiratory Spontaneous vomiting: keep head below hips to prevent aspiration; Rinse mouth and give distress and can swallow (Child: up to 4 oz. or adult: 8 oz.). do not induce vomiting. Immediately obtain medical attention. 1/2 to 1 cup of water or milk. Unconscious person: do not induce vomiting or give any liquid. Most important symptoms and effects Symptoms Inhalation may cause respiratory tract discomfort. Contact with liquid, mist or vapor can cause immediate irritation or corrosive burns to all human tissue. Severity of the burn is generally determined by the concentration of the solution and duration of exposure. Contact with water. Repeated skin contact with dilute solutions may cause dermatitis. May cause with eyes may result in permanent visual loss unless removed quickly by thorough irrigation dental erosion. May be harmful if swallowed. Indication of any immediate medical attention and special treatment needed Notes to Physician Treat symptomatically. 5. FIRE-FIGHTING MEASURES Suitable Extinguishing Media Use dry chemical or CO2 base fire extinguishers to fight surrounding fire. Unsuitable Extinguishing Media Not determined. Violent reaction with water. Evolution of explosive hydrogen gas on contact with most metals will react with organic material with Specific Hazards Arising from the Chemical evolution of heat and dense white fumes. May cause ignition of combustible materials on contact with the generation of sulfur dioxide fumes. Hazardous Combustion Products Explosive hydrogen gas is generated by the action of acid on most metals. Protective equipment and precautions for firefighters protective gear. Do not use water on acid itself. Apply from farthest possible distance. As in any fire, wear self-contained breathing apparatus pressure-demand, MSHA/NIOSH (approved or equivalent) and full 6. ACCIDENTAL RELEASE MEASURES Personal precautions, protective equipment and emergency procedures Personal Precautions Utilize full protective clothing, including boots and protective equipment. Environmental Precautions See Section 12 for additional Ecological Information. Methods and material for containment and cleaning up Methods for Containment Prevent further leakage or spillage if safe to do so Methods for Clean-Up marked containers for reclamation or disposal. If possible, neutralize on a dry basis with Contain spill in order to prevent contamination of sewage system or waterway. Pump into water in accordance with applicable regulations. Page 3/8 <<>> : API-001 - Liquid Fire Drain Line Opener Revision Date: 07-Aug-2014 7. HANDLING AND STORAGE Precautions for safe handling Advice on Safe Handling Handle in accordance with good industrial hygiene and safety practice. Use personal protective equipment as required. Do not breathe dust/fume/gas/mist/vapors/spray. Use and any exposed skin thoroughly after handlin only outdoors or in a well-ventilated area. Wear respiratory protection. Wash face, hand Conditions for safe storage, including any incompatibilities Storage Conditions Keep container tightly closed and store in a cool, dry and well-ventilated place. Store locked up. Store away from other chemicals and potential sources of contamination. Do not use Incompatible Materials carbonates and other alkaline materials. Highly reactive with materials such as metal oxides, hydroxides, nitrates, amines, 8. EXPOSURE CONTROLS/PERSONAL PROTECTION Exposure Guidelines Chemical Name Sulfuric Acid ACGIH TLV 7664-93-9 TWA: 0.2 mg/m thoracic OSHA PEL fraction (vacated) TWA: 1 mg/m? TWA: 1 mg/m IDLH: 15 mg/ma NIOSH IDLH TWA: 1 mg/m3 Appropriate engineering controls Engineering Controls Room or area must have total ventilation using open windows and/ or fans. Safety showers and eyewash fountains should be easily accessible. Individual protection measures, such as personal protective equipment Eye/Face Protection Safety glasses with side shields, goggles and/or a face shield. Skin and Body Protection suit recommended). Rubber gloves, rubber footwear and protective clothing (acid resistant hood and full body Respiratory Protection or risk of inhalation of vapors, use suitable respiratory equipment. Ensure adequate ventilation, especially in confined areas. In case of inadequate ventilation General Hygiene Considerations Handle in accordance with good industrial hygiene and safety practice. 9. PHYSICAL AND CHEMICAL PROPERTIES Information on basic physical and chemical properties Appearance Physical State Liquid Color Amber liquid Amber Odor Odor Threshold Slight pungent odor Not determined pH Property Yalues Remarks • Method Melting Point/Freezing Point Not determined Flash nint Billing Range 279 °C / 535 °F Evaporation Rate Not flammable Flammability (Solid, Gas) < than (1) Upper Flammability Limits Not determined Not available Page 4/8 <<>> API-001 - Liquid Fire Drain Line Opener Revision Date: 07-Aug-2014 Property Lower Flammability Limit Values Vapor Density Vapor Pressure Not available Vot available Remarks • Method Water Solubility Specific Gravity Not available -1.835 (Air=1) Solubility in other solvents Soluble Auto-ignition Temperature Partition Coefficient Not determined Not available Decomposition Temperature Not determined Kinematic Viscosity Not determined Explosive Properties Dynamic Viscosity Not determined Not determined Oxidizing Properties Not determined Not determined 10. STABILITY AND REACTIVITY Reactivity Not reactive under normal conditions. Stable under recommended storage conditions. Chemical Stability Possibility of Hazardous Reactions generated by the action of acid on most metals May cause ignition of combustible materials on contact with the generation of sulfur dioxide fumes. Explosive hydrogen gas is Hazardous Polymerization Hazardous polymerization does not occur. Keep out of reach of children. Conditions to Avoid Incompatible Materials Highly reactive with materials such as metal oxides, hydroxides, nitrates, amines, carbonates and other alkaline materials. Hazardous Decomposition Products Explosive hydrogen gas is generated by the action of acid on most metals. 11. TOXICOLOGICAL INFORMATION Information on likely routes of exposure Product Information Eye Contact Causes severe eye damage. Skin Contact Causes severe skin burns. Inhalation Harmful if inhaled. Ingestion May be harmful if swallowed Component Information Chemical Name Sulfuric Acid Oral LD50 7664-93-9 = 2140 mg/kg (Rat) Dermal LD50 = 510 mg/m° (Rat) 2 h Inhalation LC50 Page 5/8 <<>> API-001 - Liquid Fire Drain Line Opener Revision Date: 07-Aug-2014 Information on physical, chemical and toxicological effects Symptoms Please see section 4 of this SDS for symptoms. Delayed and immediate effects as well as chronic effects from short and long-term exposure Skin corrosion/irritation Causes severe skin burns. irritation Serious eye damage/eye Causes severe eye damage. Carcinogenicity as a known carcinogen. Note: The agencies below have listed Strong Inorganic Acid Mists, Containing Sulfuric Acid Chemical Name Sulfuric Acid ACGIH Legend 7664-93-9 A2 Group 1 LARC Known NTP OSHA (er coup toni sany and Hai administration or the us popartmentor abor) Not determined Numerical measures of toxicity 12. ECOLOGICAL INFORMATION Ecotoxicity spills can have a harmful or damaging effect on the environment. The product is not classified as environmentally hazardous. However, this does not exclude the possibility that large or frequent Component Information Chemical Name Algae/aquatic plants Fish Toxicity to Sulfuric Acid 7664-93-9 500: 96 h Brachydanio rerio microorganisms Crustacea mg/L LC50 static 29: 24 h Daphnia magna mg/L EC50 Persistence/Degradability Not determined. Not determined. Bioaccumulation Mobility Not determined Not determined Other Adverse Effects 13. DISPOSAL CONSIDERATIONS Waste Treatment Methods Disposal of Wastes regulations. Disposal should be in accordance with applicable regional, national and local laws and Page 6/8 <<>> API-001 - Liquid Fire Drain Line Opener Revision Date: 07-Aug-2014 Contaminated Packaging regulations. Disposal should be in accordance with applicable regional, national and local laws and California Hazardous Waste Status Chemical Name Sulfuric Acid California Hazardous Waste Status 7664-93-9 Corrosive 14. TRANSPORT INFORMATION Note Please see current shipping paper for most up to date shipping information, including exemptions and special circumstances. POT MID NO Proper Shipping Name UN1760 Hazard Class Packing Group LATANID NO Hazard Class Proper Shipping Name UN1760 Corrosive liquid, n.o.s. (sulfuric acid) Packing Group IMDG UNID No Hazard Class Proper Shipping Name UN1760 Packing Group 15. REGULATORY INFORMATION International Inventories Chemical Name Sulfuric Acid NDSL | EINECS Present ELINCS IECSC PICCS LeS SCA United States Toxic Substances Control Act section Bb inventory DSLINDSL - Canadian Domestic Substances List Non-Domestic Substances List EINECS/ELINCS - European Inventory of Existing Chemical Substances/European List of Notified Chemical Substances US Federal Regulations CERCLA Chemical Name Sulfuric Acid Hazardous Substances RQS 7664-93-9 1000lb CERCLA/SARA RO 1000lb Reportable Quantity (RQ) RQ 1000 Ib final RQ RQ 454 kg final RQ Page 7/8 <<>> API-001 - Liquid Fire Drain Line Opener Revision Date: 07-Aug-2014 SARA 313 Chemical Name CAS NO Weight% SARA 313 - Threshold Sulfuric Acid - 7664-93-9 7664-93-9 92.94 Values % 1.0 CWA (Clean Water Act) Chemical Name CWA - Reportable Sulfuric Acid Quantities CWA - Toxic Pollutants CWA - Priority Pollutants CWA - Hazardous 1000lb Substances US State Regulations California Proposition 65 This product contains the following Proposition 65 chemicals. Sulfuric Acid - 7664-93-9 Chemical Name California Proposition 65 Carcinogen U.S. State Right-to-Know Regulations Chemical Name Sulfuric Acid New Jersey 7664-93-9 X Massachusetts Pennsylvania 16. OTHER INFORMATION NFPA Health Hazards Not determined Flammability Instability HMIS Health Hazards Not determined Not determined Flammability hysical Hazard lot determine Not determined Special Hazards Not determined Not determined Not determined Personal Protection Revision Date: Issue Date: 01-May-2014 Revision Note: New format 07-Aug-2014 date of its publication. The information given is designed only as a guidance for safe handling, use, processing, storage, The information provided in this Safety Data Sheet is correct to the best of our knowledge, information and belief at the elates only to the specific material designated and may not be valid for such material used in combination with any othe ransportation, disposal and release and is not to be considered a warranty or quality specification. The informatio materials or in any process, unless specified in the text. End of Safety Data Sheet Page 8/8 - **truncated:** false - **body characters:** 23462