Guidanceguidance
16-0080
Technology Solutions — Hazardous Materials Safety Interpretation
Current as of source date Government source
RegulusPipeline researchRegulusPipeline research16-0080
Page 1of Transportation U.S. Department 1200 New Jersey Avenue, SE Washington, D.C. 20590 Pipeline and Hazardous Materials Safety Administration AUG 0 2 2016 Mr. William Weddle NA Logistics/Warehousing Manager Technology Solutions 1 Heilman Avenue Willow Island, WV 26134 Reference No. 16-0080 Dear Mr. Weddle: This letter is in response to your May 5, 2016 email and May 27, 2016 emails, attachments, and telephone conversation requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the transport of a two-part prepolymer-urethane system that becomes reactive when mixed. Specifically, you state this system consists of two cartridges—one that contains a curative and the other that contains a prepolymer-placed side by side in a manual or pneumatic dispenser with one point opening at the end that is designed to permit the combination of these materials before application. In addition, you provide the following information: • Your company sells two types of curatives it describes as "DM-5183, Part A Curative," and "DPDM-28502, Part B Urethane Curative." It has assigned both curatives the proper shipping description "UN 3082, Environmentally hazardous substance, liquid, n.o.s., 9 (miscellaneous), Packing Group (PG) III (Phenylmercuric acetate, Marine Pollutant." • Your company sells two types of prepolymers it describes as "DPDM-28502, Part A Urethane Prepolymer" and "DM-5183, Part B Urethane Prepolymer." It has assigned Part A prepolymer the proper shipping description "UN 2810, Toxic liquid, organic, n.o.s, 6.1, PG II (4,4"-methylenedicyclohexyl diisocyanate)," and Part B prepolymer the proper shipping description "UN 2290, Isophorone diisocyanate mixture, 6.1 (poisonous), PG III." Combined, the two cartridges contain either 200 mL or 400 mL of liquefied material. Part A and B materials create a mild exothermal reaction of 50 °C (122 °F) to 60 °C (140 °F) for a few minutes when mixed until the resin has cured.#
Page 2We have paraphrased and answered your questions as follows: Q1. You ask for the definition of "dangerous evolution of heat" under the HMR. Al. While the HIMR do not specifically define "dangerous evolution of heat" it is described as "an amount of heat sufficient to be dangerous to packaging or personal safety to include charring of packaging, melting of packaging, scorching of packaging, or other evidence" in examples provided in the following sections: $8 171.15(b)(6); 171.16(b)(5); 172.102(c), Special Provision 130, paragraph (a); and 173.159a(b). Further, § 173.21(e) states that a material may not be placed in the same packaging, freight container, or overpack with another material if, when mixed, these materials may possibly cause a dangerous evolution or heat; flammable or poisonous gas or vapor; the formation of a corrosive material. In addition, § 173.24(e)(4) requires that the materials may not form an asphyxiant gas or unstable material. Q2. You ask if the Part A and B prepolymer-urethane materials you described can be shipped as a two-part, joint plunger-type system in an inner packaging that is placed in a United Nations (UN) 4G fiberboard box. A2. The answer is yes. Section 173.24a(c)(1)(ii) requires packages of mixed contents to meet the performance test criteria in Part 178 of the HMR and to conform to the relevant packaging sections of Part 173 that apply to each material within the packaging. You discussed with my staff the possibility that that material may be described as "UN 3269, Polyester resin kit, 3 (flammable liquid)"; however, please note this description applies to kits consisting of Class 3 and Division 5.2 (organic peroxide) only. Q3. You ask if the HMR require completed packages that contain samples of the joint- plunger cartridge system you described to have a UN marking and certification. A3. If shipped as a limited quantity and a determination is made that the mixing of the flammable or poisonous gases or vapors, or corrosive materials, a UN standard materials in the same packaging is not likely to cause a dangerous evolution of heat, packaging is not required. Limited quantity packagings are excepted from the specification packaging requirements of the HMR. I hope this information is helpful. Please contact us if we be of further assistance. Sincerely, T. Glenn Foster Chief, Regulatory Review and Reinvention Branch Standards and Rulemaking Division 2#
Page 3Edmonson • 173.21 Goodall, Shante CTR (PHMSA) subidden Matemals and parkaes From: INFOCNTR (PHMSA) 10-00x0 Sent: Friday, May 06, 2016 12:03 PM To: Hazmat Interps Subject: FW: HMR 49CFR Parts 171-180 173.21 173.24 Attachments: DOT Cartridge.docx Hi Shante/Alice, Please submit this as a letter of interpretation. I spoke with Mr. Weddle. Please let me know if you have any questions. Thanks, Jordan From: Weddle, William [mailto: william.weddle@solvay.com] To: INFOCNTR (PHMSA) Sent: Thursday, May 05, 2016 10:50 AM Subject: HMR 49CFR Parts 171-180 173.21 173.24 Please review and advise. Thank You, - William Weddle Technology Solutions NA Logistics/Warehousing Manager T+1 304-665-3605 M+1 304-919-8879 SOLVAY www.solvay.com Connect with Solvay: Info recevez ce message par erreur, merci de le detruire et d'en avertir immediatement l'emetteur. Toute copie, transmission ou divulgation, integrale ou partielle, par Ce message, ainsi que toute piece jointe, est exclusivement adresse au(x) destinataire(s) nomme(s) et peut contenir des informations confidentielles. Si vous#
Page 4'us. ou tout autre procede seraient contenus dans ce messade ou toute piece ioin e personne qui n'est pas nommee comme destinataire est interdite. Nous utilisons un logiciel anti-virus mais nous denions toute responsabilite au cas ou d#
Page 5U.S. Department of Transportation May 5, 2016 Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Avenue, SE East Building, 2nd Floor Washington, DC 20590 Parts 171-180). Packaging of cartridges and Regulatory reference regarding mixing of reactive materials; 173.21, We are requesting Clarification regarding the application of the Hazardous Materials Regulations (HMR; 49 CFR We have several products that we would like to ship in a joined syringe type cartridge so the customer could get a constant mixture flow from the tip to allow for optimal performance of the product. The products Part A & Part B are currently packed in a single cartridge and the two parts are shipped in separate 4G boxes. We have a mixture of Hazardous and NON Hazardous Parts A and B. DM-5183 Part A Curative Proper Shipping Name: Environmentally hazardous substance, liquid, n.o.s. Packing Group: III Hazard Class: 9 UN/ID Number: UN3082 Marine Pollutant Transport Label Required: Miscellaneous Marine Pollutant Technical Name (N.O.S.): Phenylmercuric acetate Hazardous Substances only apply if the quantity in one package equals or exceeds Hazardous Substances/Reportable Quantities - DOT requirements specific to Marine Pollutants - DOT requirements specific to Marine Pollutants do not apply to the product reportable quantity. non-bulk packagings transported by motor vehicles, rail cars or aircraft DM-5183 Part B Urethane Prepolymer Hazard Class: 6.1 Proper Shipping Name: Isophorone disocyanate mixture Packing Group: Ill Transport Label Required: Toxic JN/ID Number: UN2290 DPDM-28502 Part A Urethane Prepolymer Proper Shipping Name: Toxic liquid, organic, n.o.s. Packing Group: 1 Transport Label Required: Toxic IN/ID Number: UN281 Technical Name (N.O.S.): 4,4'-methylenedicyclohexyl disocyanate#
Page 6DPDM-28502 Part B Urethane Curative Hazard Class: 9 Proper Shipping Name: Environmentally hazardous substance, liquid, n.o.s. Packing Group: Ill Transport Label Required: Miscellaneous UN/ID Number: UN3082 Marine Pollutant Marine Pollutant Technical Name (N.O.S.): Phenylmercuric acetate Marine Pollutants - DOT requirements specific to Marine Pollutants do not apply to non-bulk packaging's transported by motor vehicles, rail cars or aircraft. The cartridges are sample shipments; I have attached the type of cartridges we would prefer to The size relates to the total volume capacity of both sides of the cartridges 50 ml 200mL cartridge Systems (1). pdf 400mL cartridge Systems (1). pdf For Clarification mixed. Q1: What is the definition of "dangerous evolution of heat"? Parts A & B create a Mild exothermal of 50C to 60C when box? Q2: Can Parts A&B be shipped in a two part joined plunger type cartridge as an inner package in a 4G Fiberboard Q3: For the Hazardous sample shipments is it a requirement that the cartridge have a UN marking and certification? Sincerely, William C. Weddle William Weddle Technology Solutions NA Logistics/Warehousing Manager T+1 304-665-3605 M+1 304-919-8879 #1 Heilman Ave. Willow Island WV 26134#
Page 7William.Weddle@soivay.com#
This material provides agency context. It does not replace binding regulatory text, and its legal effect depends on the underlying authority and facts.