{"operation":"document","citation":"15-0209","title":"Renessenz LLC. — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2016-02-23","effective_on":null,"summary":"15-0209 response to Renessenz LLC. concerning 172.101.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-15-0209.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-15-0209.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-15-0209","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2016/150209.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\nFEB 2 3 201b\n1200 New Jersey Avenue, SE\nWashington, D.C. 20590\nMr. John M. Hinson\nManager, Strategic Raw Materials\nRenessenz LLC.\n601 Crestwood St.\nJacksonville, FL 32208\nRef. No.: 15-0209\nDear Mr. Hinson:\nThis is in response to your October 14, 2015 email, requesting clarification on the correct\nbasic description for crude sulfate turpentine solution (CST). Specifically, you ask whether\nthe most appropriate proper shipping name for this commodity is \"UN1993, Flammable\nliquids, n.o.s., Class 3\" or \"UN1299, Turpentine, Class 3.\" You note that depending on the\namount of sulfur compounds present in the solution, the flash point may result in either a\npacking group II or III assignment. For UN1299, the§ 172.101 Hazardous Materials Table\n(HMT) only contains a packing group III entry.\nSection 172.101 ( c )(10) sets forth the criteria for selecting a proper shipping name of a mixture\nor solution not identified specifically by name in the HMT. Section 172.lOl(c)(lO)(i)\nrequires that a mixture or solution comprised of a single predominant hazardous material\nidentified by technical name in the HMT and one or more hazardous and/or non-hazardous\nmaterial must be described with the proper shipping name of the predominant hazardous\nmaterial and the qualifying word \"mixture\" or \"solution,\" unless the mixture or solution meets\none or more of the conditions in subparagraphs (i)(A) through (F).\nThe CST you describe is in solution that is not identified by name in the HMT, but is comprised\nof a single predominant hazardous material (Turpentine) identified in the HMT by technical\nname and one or more hazardous and/or non-hazardous materials. As such, the most appropriate\nbasic description for the CST assigned to PG III is \"UN1299, Turpentine solution, Class 3, PG\nIII.\" However, in accordance with§ 172.lOl(c)(lO)(i)(C), CST meeting the criteria for PG II\nmay not be described as \"UN1299\" because the packing group of the solution is different from\nthat specified in the entry. A solution of turpentine meeting the criteria of a PG II flammable\nliquid and no other hazard class must be assigned to an appropriate description such as\n\n<<<PAGE 2>>>\n\n\"UN1993, Flammable liquids, n.o.s.\" The requirements for generic or \"n.o.s.\" proper shipping\nname selection in § 172.101 ( c )(1 O)(iii) are intended for mixtures or solutions not comprised of a\nsingle predominant hazardous material identified in the HMT.\nI trust this information is helpful. If you have further questions, please do not hesitate to\ncontact this office.\nSincerely,\nDuane A. Pfund\nInternational Standards Coordinator.\nStandards and Rulemaking Division\n\n<<<PAGE 3>>>\n\nlJ LLJ'\\.-Ul.\nf 17~~\").\n~~\n15-DZOCf\nDodd, Alice (PHMSA)\nFrom:\nSent:\nTo:\nSubject:\nAttachments:\nGeller, Shelby CTR (PHMSA)\nWednesday, October 14, 2015 4:01 PM\nHazmat Interps\nFW: Interpretation Request\nPHMSA letter UN 1993 vs UN 1299 Oct 2015.docx\nDear Shante and Alice,\nAttached is a request for a formal letter of interpretation.\nThanks,\nShelby\nFrom: Hinson, John M. [mailto:John.Hinson@renessenz.com]\nSent: Wednesday, October 14, 2015 10:14 AM\nTo: PHMSA HM InfoCenter\nCc: Jerry Smith (jerry.smith@iff.com)\nSubject: Interpretation Request\nTo Whom It May Concern,\nPlease find attached an interpretation request letter concerning the UN placarding of crude sulfate turpentine.\nWe look forward to your interpretation and welcome any questions that you may have.\nThank you.\nRegards,\nJohn\nJohn M. Hinson\nManager, Strategic Raw Materials\nRENESSENZ LLC\n601 Crestwood St.\nJacksonville, FL 32208\nPO Box 389 (32201-0389)\nUSA\nTel +1 904 924 2853\nFax +1 904 924 2826\nMobile +1 904 226 0430\njohn.hinson@renessenz.com\nrenessenz. com\nJerry A. Smith\nSr. Recovery Engineer\nInternational Flavors & Fragrances\nCell Phone904-891-1547\n1\n\n<<<PAGE 4>>>\n\nTo Whom It May Concern,\nWe would like to make an interpretation letter request of the PHMSA. This request is to clarify the\nselection and use of UN 1299 vs. UN 1993 NOS for shipments of crude sulfate turpentine from paper\nmills in the USA.\nWe are employed by two large processor's of crude sulfate turpentine (CST) and are also member's of\nthe Pine Chemicals Association. Our companies receive rail tank cars (and tank trucks) of CST daily from\npulp and paper mills throughout the U.S. and Canada. CST is a by-product of the Kraft papermaking\nprocess.\nIn the USA and Canada today, the type of turpentine produced is the by-product from the papermaking\nprocess and as described above it is commonly called CST, or crude sulfate turpentine, or just\nturpentine. Some folks also refer to it a pulp mill liquid.\nDuring the first half of the twentieth century and earlier, it was common for oleoresin (the \"dip\" or\n\"gum\" or \"tar\") to be collected from pine trees. This oleoresin was sent to Naval Stores processing\nplants where it was cooked in a large kettle or reactor. Rosin and gum turpentine were the products\nmade from this Naval Stores process. As you probably know, this industry is essentially extinct now in\nthe USA.\nHowever, in parts of the world today such as China, Brazil and Indonesia, the practice of collecting tree\noleo resin is widely practiced. The type of turpentine derived from the tree oleo resin is called gum\nturpentine. The gum turpentine and crude sulfate turpentine are both technically turpentine as they\ncontain common compounds such as alpha-pinene, beta-pinene and myrcene. However, there is an\nimportant difference between gum turpentine (GT) and crude sulfate turpentine (CST).\nGum turpentine is pure in the sense that it is the essential oil of the pine tree and has no\ncontaminants. CST on the other hand is turpentine too, but it contains other compounds from the\nKraft pulping process that can and do affect its properties - especially its flash point.\nLet me give you some specific examples to illustrate the differences in CST and GT:\nGum turpentine, also, known as \"spirit of turpentine\" or \"oil of turpentine\" is pure turpentine and is\nmostly alpha-pinene + beta-pinene and no contaminants and will always have a flash point near 100\ndegrees F. This would place this gum turpentine in Packing Group Ill for Class 3 flammable liquids.\nCrude sulfate turpentine on the other hand, CST, will always have varying amounts of sulfur compounds\npresent in solution with the turpentine. It is the same pure turpentine as described above for gum\nturpentine, but with one major difference - it is contaminated with other compounds from the paper\nmaking process. The pulping conditions and sulfidity of the cooking liquor affect the amount of sulfur\ncompounds present in the turpentine. Generally speaking, there is a strong correlation between sulfur\ncontent of CST and the flash point of the CST. It is an inverse relationship. For example, as the total\nsulfur content increases in CST, the flash point decreases. Our company tests for sulfur content and flash\npoint using the latest analytical techniques and equipment. I will give a few random examples to\nillustrate the relationship between sulfur content and flash point at Kraft mills in the southeastern USA:\nMill A 2,394 ppm sulfur and 91 degrees F flash point (PG Ill)\n\n<<<PAGE 5>>>\n\nMill B 8,516 ppm sulfur and 81 degrees F flash point {PG Ill)\nMill C 11,822 ppm sulfur and 62 degrees F flash point {PG II)\nMill D 15,057 ppm sulfur and 26 degrees F flash point {PG II)\nPlease note that three main sulfur compounds are typically found in CST: methyl mercaptan, dimethyl\nsulfide and dimethyl disulfide. The amounts and ratio of these compounds vary depending on pulping\nconditions etc. These sulfur compounds have the effect of lowering the flash point of the CST and thus\nchanging its properties related to fire and explosion hazards.\nIn the example above we can see that there is a large variation in sulfur contents and the corresponding\nflash points.\nIn a survey of our industry {the processors of turpentine), the majority of shippers of CST utilize UN 1993\nplacarding to comply with DOT regulations. They specify \"crude sulfate turpentine\" on the Bill of Lading\nand the MSDS {now SDS) contains UN 1993 in the Transport Information section of the SDS.\nThe purpose of this letter is to seek clarification from PHMSA on what UN number is most appropriate\nfor use with shipments of crude sulfate turpentine - UN 1993 or UN 1299?\nIn closing, please allow us to summarize some key points for your consideration:\nGum turpentine is essentially no longer commercially produced in the USA. It is considered the essential\noil of the pine tree and is pure. UN 1299 references \"oil of turpentine\" and \"spirit of turpentine\" and this\nagrees and fits with gum turpentine. Again, this type turpentine is mostly produced outside the USA.\nCrude sulfate turpentine is the commercial product produced as a by-product of the paper making\nprocess and is common in the USA {and Canada). It is contaminated with various sulfur compounds\nproduced in the Kraft papermaking process. These contaminants significantly alter the properties of the\nCST and it becomes dissimilar from gum turpentine in its fire and explosive hazards and risks.\nIt is our opinion that CST should be classified as UN 1993 NOS {crude sulfate turpentine) and PG II or PG\nIll as appropriate. The majority of shippers of CST today utilize the UN 1993 placard and this has been\nthe case for many decades. We are aware of only one paper company that prefers to use the UN 1299\nplacard.\nWe would appreciate your timely clarification and opinion on whether UN 1993 or UN 1299 is most\nappropriate for use with CST shipments in the USA today.\nThanks kindly and please feel free to contact Jerry Smith or me with any questions or if you wish\nclarification on any points in this letter.\nThank you.\n\n<<<PAGE 6>>>\n\n\" '\nRegards,\nJohn\nJohn M. Hinson\nManager, Strategic Raw Materials\nRENESSENZ LLC\n601 Crestwood St.\nJacksonville, FL 32208\nPO Box 389 (32201-0389)\nUSA\nTel +1 904 924 2853\nFax +1 904 924 2826\nMobile +1 904 226 0430\njohn.hinson@renessenz.com\nrenessenz.com\n~ENESSENZ\nJerry A. Smith\nSr. Recovery Engineer\nInternational Flavors & Fragrances\nCell Phone904-891-1547","truncated":false,"body_characters":10169}