# Scarpa Consultants — Hazardous Materials Safety Interpretation

- **operation:** document
- **citation:** 18-0087
- **title:** Scarpa Consultants — Hazardous Materials Safety Interpretation
- **source type:** guidance
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** guidance
- **official:** true
- **published on:** 2019-02-04
- **effective on:** Not available
- **summary:** 18-0087 response to Scarpa Consultants concerning 173.124, 173.22.
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-interpretation-18-0087.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-interpretation-18-0087.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-interpretation-18-0087
- **source url:** https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/standards-rulemaking/hazmat/interpretations/70336/180087.pdf
**body:**

<<<PAGE 1>>>

U.S. Department
of Transportation
1200 New Jersey Avenue, SE
Washington, DC 20590
Pipeline and Hazardous
FEB 0 4 2019
Materials Safety
Administration
Nicholas Scarpa, Ph.D.
Scarpa Consultants
8 Troon Drive
Fredon, NJ 07860
Reference No. 18-0087
Dear Mr. Scarpa:
i lete is in repairs to rulen, 7, EUl orator and and company mai and
Paraform, also described in the documents as "Company B") of Mainz, Germany. Your client
requests clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180)
applicable to the classification of Granuform® 91 and Granuform® 96, materials that contain 91
and 96 percent "UN2213, Paraformaldehyde, Division 4.1 (flammable solid), Packing Group
(PG) III," respectively. Specifically, you ask if materials that contain less than 18 parts per
million (ppm) of sodium and less than 100 ppm of alkali metal ions and/or other metal ions as
impurities do not meet the definition of a Division 4.1 (flammable solid) material as defined in
§ 173.124(a) of the HMR.
You enclosed several documents and test reports listed in the attachment to this letter but ask that
we limit our response to two INEOS Paraform products: Paraformaldehyde B-1 (91%) and B-2
(96%). We have paraphrased the information on these materials that you and your client
provided in the table below.
Ref. Substance Name!| Preliminary
Wetting
Alkali Metal lon &
Sample Test
No.
(Trade Name:
Granuform®)
screening
solution
Result
test
Other Content
Performance
delay
time
(min)
6.d
Paraformaldehyde
Negative
B-1 (91%)
N/A
Sodium content <
Sample when heated
NOT to
(<2 ppm Nat)
(flame died)
2 ppm, < 5 ppm
with a gas burner
other alkali metal
melted forming a
classified
be
Performed by Laus
ions,
liquid, the liquid
2 other metal ions
found in
started to boil and
as
boiling spot burned
Division
4.1
concentrations of
with a flame. The
7 and 9 ppm,
flame died on its own
2 UN Test N.1, section 33.2.1.4.3.1: ignition or propagation of combustion within 2 minutes.
1 Paraformaldehyde Assay expressed in available % formaldehyde in brackets.

<<<PAGE 2>>>

respectively, in a
when no boiling test
screening test on
36 different metal
item was present.
< 300 ppm Formic
elements by ICP,
acid
6.e
Paraformaldehyde
Negative
N/A
Sodium content 5
Sample was ignited
NOT to
B-2 (96%)
(combustion
ppm, <5 ppm
with a flame of a
15 ppm Nat)
took > 29
other alkali metal
Teclu burner. First
classified
be
minutes)
ions,
melting was
(Granuform® 96)
2 other metal ions
observed, then the
Division
as
found in
test item started to
4.1
concentrations of
burn with 2 seats of
10 and 13 ppm,
fire after 12 seconds.
respectively, in a
Melting and no
screening test on
formation of smoke
36 different metal
were observed.
elements by ICP,
Combustion along
< 300 ppm Formic
200mm took 29
acid
minutes and 37
seconds.
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. However, based on the
information you provided, it is the opinion of this Office that the tested materials in Reference
Nos. 6.d and 6.e do not exhibit criteria exceeding the limit specified in § 173.124(a)(3)(ii) and,
therefore, do not meet the definition of a Division 4.1 readily combustible solid.
I hope this information is helpful. Please contact us if we can be of further assistance.
Sincerely,
tern Tote
T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division
Attachment

<<<PAGE 3>>>

Clarification Letter Reference No. 18-0087
Attachments
You state you provided all data related to INEOS Paraform products, including the LAUS and
ICP reports. The following is the list of materials you provided with your correspondence.
• Analyses and flammability final test reports dated June 9, 2010, and June 17, 2011, Study
Numbers 10042301G934UN and 11051101G934, respectively, performed by the LAUS
GmbH test facility in conformance with the United Nations (UN) Manual of Tests and
Criteria UN Test N.1, Section 33.2.1.4.3.1.
• A document titled "Expert opinion on transport classification of paraformaldehyde,"
prepared by GBK Gefahrgut Büro BmbH and signed on December 8, 2010.
• A diagnostic analysis of Paraformaldehyd (Granuform® 91 Charge G120228) dated
March 2, 2012.
• A diagnostic analysis of Bestimmungvon NA im Paraformaldehyd (Granuform®) dated
March 26, 2012.
• A report prepared for the UN Committee of Experts on the Transport of Dangerous
Goods and on the Globally Harmonized System of Classification and Labelling of
Chemicals titled "Classification under UN 2213 (Paraformaldehyde)," dated July 31,
2013, that concluded fine and/or granulated "Paraformaldehyde should not be classified
as a readily combustible solid of Division 4.1, if the test material contains less than
100 pps of alkali metal ion." This report states six of the nine products tested do not meet
the definition of a flammable solid.
• INEOS Paraform Product Information Granuform® Paraformaldehyde, For
Granuform_12E, May 2012.
3

<<<PAGE 4>>>

Edmonson
January, Ikeya CTR (PHMSA)
Testinsos7
From:
INFOCNTR (PHMSA)
Sent:
Friday, June 08, 2018 3:28 PM
To:
Hazmat Interps
Subject:
FW: INEOS Paraformaldehyde Classification.
Attachments:
ATT_1 Paraformaldehyde_UN Proposal_2013.pdf; ATT_ 2 Paraformaldehyde_Flammability
Test. 2010. pdf; ATT_3 Paraformaldehyde_Flammability Test 2011.pdf; ATT_4
Paraformaldehyde_Granuform 91_Sodium content.pdf; ATT_5
Paraformaldehyde_Granuform M_Sodium content.pdf; ATT_6 Paraformaldehyde_GBK
expert statement transport classification paraformaldehyde 2010,pdf
Hello Ikeya and Alice,
I searched the Database, and there wasn't anything that spoke of this situation directly. I have also spoken with Mir.
Scarpa and he said that he would like a Letter of Interpretation. I also advised him that he may also need to apply for an
approval to be able to move this material within the United States and an unregulated material.
Regards,
-Breanna
From: Nick Scarpa [mailton.scarpa@gok-fredon.usl
Sent: Thursday, June 07, 2018 12:18 PM
To: INFOCNTR (PHMSA) < INFOCNTR.INFOCNTR@dot.gov>
Subject: INEOS Paraformaldehyde Classification.
Dear Info Center Staff,
I am writing on behalf of my client;
INEOS PARAFORM GmbH
Hauptstrasse 30
55120 Mainz
Germany
The company produces two products that are paraformaldehyde solid.
Paraformaldehyde solid is currently classified under UN 2213, class 4, packing group III.
INEOS has conducted relevant flammability studies on their product an have concluded that they are not
flammable solids as defined.
This conclusion has been confirmed in a proposal by the UN Committee of Experts on the Transport of
Dangerous Goods. (see ATT_1), as well as GBK Gefahrgut Buro (see ATT_6).
Also attached are the analyses and flammability testing reports that were done. (see ATT_2 through ATT_5)
1

<<<PAGE 5>>>

Therefore, we are requesting that the US DOT PHMSA also provide a formal letter of interpretation that the
INEOS paraformaldehyde products are not flammable solid materials under the US Hazardous Materials
Transportation regulations.
Please feel free to contact me with any questions or require further information.
Sincerely,
Nicholas Scarpa
Scarpa Consultants
Nicholas Scarpa Ph.D.
8 Troon Drive
Fredon, NJ, 07860
Office Phone: 973 579 9750
Mobile Phone: 201 572 9157
Fax: 973 721 6308
e-mail n.scarpa@gbk-fredon.us
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