# TerraTrike — Hazardous Materials Safety Interpretation - **operation:** document - **citation:** 19-0088 - **title:** TerraTrike — Hazardous Materials Safety Interpretation - **source type:** guidance - **agency:** Pipeline and Hazardous Materials Safety Administration - **status:** guidance - **official:** true - **published on:** 2020-05-06 - **effective on:** Not available - **summary:** 19-0088 response to TerraTrike concerning 172.102, 173.185, 173.220. - **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-interpretation-19-0088.json - **markdown:** https://regulus.evalyn.ai/document/phmsa-interpretation-19-0088.md - **app url:** https://regulus.evalyn.ai/document/phmsa-interpretation-19-0088 - **source url:** https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/standards-rulemaking/hazmat/interpretations/73801/190088.pdf **body:** <<>> U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Avenue, SE Washington, DC 20590 May 6, 2020 Ms. Lisa Permesang Accounting/Logistics TerraTrike 4460 40th Street SE Grand Rapids, MI 49512 Reference No. 19-0088 Dear Ms. Permesang: This letter is in response to your April 22, 2019, letter, forwarded to this Office by email on July 1, 2019; your August 27 and 28, 2019, and September 19 and 25, 2019, emails that you provided to a member of my staff; and your November 15, 2019, email that you provided to Mr. Steve Hwang, Chemist, Sciences Branch, Sciences Engineering and Research Division, Pipeline and Hazardous Materials Safety Administration (PHMSA). You request clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to hazardous materials classification. Specifically, you ask us to confirm the classifications for an electric- assist (e-assist) tricycle named “TerraTrike,®” manufactured by WizWheelz, Inc., that is powered by a battery classed as “UN3480, Lithium ion batteries, Class 9 (miscellaneous),” and an aftermarket e-assist kit designed to be installed on the tricycle. You enclosed images of the battery installed in its holder and attached to the tricycle frame with a mounting bracket; the e-assist kit, which consists of the battery charger, the battery in its holder, an electric motor, and appropriate mounting equipment for attachment to the tricycle; and the e-assist kit surrounded in form-fitting foam placed in a fiberboard box labeled with a Class 9 label. You state the kit complies with § 173.185(b) of the HMR and the battery in its holder complies with the International Civil Aviation Organization (ICAO) Technical Instructions for the Safe Transport of Dangerous Goods by Air (Technical Instructions), Chapter 4, Packing Instruction 952. You expressed support for § 172.102(c)(1), Special Provision 134, which states that an electrically powered vehicle can be an example of a “mobility aid,” and clarification letter Reference No. 08-0173 (dated 08/12/08), which states that an electric bicycle that complies with § 173.185 in conformance with § 173.220(d) must be described as “UN3171, Battery powered vehicle, Class 9.” Q1: You state WizWheelz, Inc., requests confirmation that it may classify its e-assist tricycle TerraTrike®, powered by a “UN3480” lithium ion battery, as “UN3171, Battery powered vehicle, Class 9,” under the HMR. <<>> A1: When the lithium battery is installed in the tricycle, the answer is yes. Special Provision 134 of § 172.102(c)(1) requires that a battery must be installed in a vehicle to use the UN3171 proper shipping description. Also, as you noted earlier, a vehicle powered by a lithium battery must satisfy the requirements of § 173.220(d), which states that the battery design type must successfully pass each test in the United Nations Manual of Tests and Criteria, as specified in § 173.185, unless approved by PHMSA’s Associate Administrator of Hazardous Materials Safety. Q2: You ask PHMSA to confirm whether “UN3481, Lithium ion battery contained in equipment, Class 9,” or “UN3171, Battery powered vehicle, Class 9,” would be the proper classification for the BOSCH Boost Kit, an aftermarket e-assist kit that is sold separately to be installed on the TerraTrike® tricycle. A2: Based on the information you provided, the e-assist kit consists of a lithium ion battery wired to a motor that is secured to and covered by its holder at the time of shipping. Therefore, it is the opinion of this Office that this battery in this kit is most appropriately described as “UN3481, Lithium ion batteries contained in equipment, 9.” The HMR defines equipment as a “device or apparatus for which the lithium cells or batteries will provide electrical power for its operation.” See § 173.185, introductory paragraph. I hope this information is helpful. Please contact us if we can be of further assistance. Sincerely, T. Glenn Foster Chief, Regulatory Review and Reinvention Branch Standards and Rulemaking Division <<>> Dodd, Alice (PHMSA) From: Sent: To: Subject: Attachments: INFOCNTR (PHMSA) Monday, July 01, 2019 4:35 PM Hazmat Interps FW: Request for Letter of Interpretation Determination Request PHMSA - Sent 04.22.2019.pdf; Bosch PowerPack 400 MSDS.pdf Hello Alice and lkeya, Please see the attached documents for a letter of interpretation request. Thanks, Lynsie, HMIC From: Lisa Permesang [mailto:lisa@terratrike.com] Sent: Monday, July 1, 2019 7:03 AM To: INFOCNTR (PHMSA) Subject: Inquiry regarding Determination letter - sent 04.22.2019 Good morning, PHMSA staff - I am not certain to whom I need to follow up with regarding a determination request we mailed to your offices in April and have yet to receive a response. I do know that this can take some time, but we are now at the 1st of July, so I just wanted to check in. I have attached a .pdf copy of the original letter and the Safety Data Sheet I had included with my original mailing. On this MSDS, I have highlighted the exact battery pack that we are using with our product. Please advise if there is anything further I need to do or if there is a specific individual that I should be directed to. I thank you in advance for your assistance and I look forward to hearing from you . Best Regards, Terra Trike® RID E IN COMFORT LISA PERMESANG ACCOUNTING / LOGISTICS 616-455-5988 x51 lisa@terratinke.com www.terratrike.com 44blJ4lJll1 ,t al 1<,1d11dl->> April 22, 2019 Mr. Shane Kelley Director, Standards and Rulemaking Division U.S. DOT/PHMSA (PHH-10) 1200 New Jersey Avenue SE East Building, 2nd Floor Washington, DC 20590 RE: Interpretation for the Proper Classification of our E-Tricyle and our Aftermarket E-Assist kit Dear Mr. Kelley: I am writing for two reasons today, as stated above. The second, of which, I will have additional inquiries. (1) WizWheelz Inc is requesting confirmation from your office that our electric-assist tricycle (TerraTrike Electric powered by a lithium ion battery can be classified and shipped as a battery powered vehicle (UN3171). Exhibit A contains a picture of this tricycle and more specifically how the battery is attached to the frame. In 2008, your office issued a letter to Cannondale Sports Group (Ref. No. 08-0173) citing that "An electric bicycle powered by a lithium-ion battery is most appropriately described as a "Battery-powered vehicle" under the HMR. A vehicle powered by a lithium battery must satisfy the requirements of§ 173.220(d), which requires the battery to be of a type that has successfully passed each test in the UN Manual of Tests and Criteria as specified in§ 173.185, unless approved by the Associate Administrator." Our trike is similar and is shipped with the battery installed on the frame in order to prevent short circuiting, etc. I am including a copy of the applicable Safety Data Sheet for the lithium ion battery included with this trike. We hold the same arguments as Cannondale Sports Group in that "Therefore, we are of the opinion that the correct classification for the electric bicycle with a lithium ion battery installed is Battery powered vehicle or Battery powered equipment (UN3171). This would be consistent with the language contained in Special Provision 134 that states "Examples of such items are electrically powered cars, lawn mowers, wheelchairs, and other mobility aids." (Emphasis added.) This classification also is consistent with how these types of bicycles are being packaged and offered for transport in Europe where these products are widely used." TerraTrike · 4460 40th St. SE Grand Rapids, Ml 49512 616.608.8086 I 800.945.9910 I www.TerraTrike.com <<>> Terra Trike® Exhibit A (2) Our aftermarket BOSCH Boost Kit, is an e-assist kit sold separately to be installed on a Terra Trike tricycle that was without thee-assist option at the original time of purchase. Please see the following pictures on the following page in Exhibit B. Our question here is also regarding the proper classification for this product. Could your office confirm whether UN3481 or UN3171 would be the proper classification for this product? The kit as it is packaged below is being offered for transportation pursuant to the packaging requirements of§ 173.185 (b) . The battery is shipped mounted in its holder in order to prevent short circuits, and then placed in the molded foam designed specifically for the shipment of this kit in order to prevent any damage. Only one battery per kit is shipped. The final picture of Exhibit B shows our identification of this product as UN3481 Lithium Ion Battery contained in Equipment. However, Packing Instructions 952 for shipment of UN3171 requ ires also that the batteries must be installed and securely fastened in the battery holder of the vehicle, machine or equipment and must be protected in such a manner so as to prevent damage and short circuits. And, in fact, the battery is installed in its holder. TerraTrike· 4460 40th St. SE Grand Rapids, Ml 49512 616.608.8086 I 800.945.9910 I www.TerraTrike.com <<>> Terra Trike® Exhibit B Thank you for in advance for your assistance in this clarification. If you have any further questions regarding our product, the lithium ion battery and the shipping materials, please do not hesitate to contact me using the details in my signature below. We look forward to receiving your determination. Sincerely, ) j;_ Lnz-"-"'!£t ✓ ~r --, LISA PERMESANG ACCOUNTING/ LOGISTICS 616-455-5988 x51 lisa@terratirike.com TerraTrike· 4460 40th St. SE Grand Rapids, Ml 49512 616.608.8086 I 800.945.9910 I www.TerraTrike.com <<>> Battery Pack Rack black 400Wh / 0275.007.505 / 36Vx40, 11 Ah, 400 Wh / 370*75*120 2,6 PowerPack 300 Active Line Frame platinum / 0275.007.509 / 36Vx30, 8,2 Ah, 300 Wh / 320*90*90 PowerPack 400 Active Line Frame platinum / 0275.007.510 / 36Vx40, 11 Ah, 400 Wh / 320*90*90 PowerPack 300 Performance Line Frame anthracite / 0275.007.511 / 36Vx30, 8,2 Ah, 300Wh/ PowerPack 400 Performance Line Frame anthracite / 0275.007.512 / 36Vx40, 11 Ah, 400 Wh / 320*90*90 2,4 PowerPack 400 Performance Line USA Frame anthracite / 0275.007.524 / 36Vx40, 11 Ah, 400 Wh/ 320*90*90 2,4 PowerPack 400 Active Line USA Rack platinum / 0275.007.526 / 36Vx40, 11 Ah, 400 Wh / 320*90*90 2,4 PowerPack 500 Active Line Frame platinum / 0275.007.529 36Vx40, 13,4 Ah, 500 Wh / 320*90*90 2,6 PowerPack 500 Performance Line Frame anthracite / 0275.007.530 36x40, 13,4 Ah, 500 Wh/ 320*90*90 2,6 PowerPack 300 Active Line Rack platinum / 0275.007.513 / 36Vx40, 8,2 Ah, 300Wh / 370*122*76 PowerPack 400 Active Line Rack platinum / 0275.007.514 / 36Vx40, 11 Ah, 400 Wh / 370*122*76 PowerPack 400 Performance Line Rack anthracite / 0275.007.522 / 36Vx40, 11 Ah, 400 Wh / 370*122*76 PowerPack 400 Performance Line USA Rack anthracite / 0275.007.525 / 36Vx40, 11 Ah, 400 Wh/ 370*122*76 2,6 PowerPack 500 Active Line Rack platinum / 0275.007.531 / 36Vx40, 13,4 Ah, 500 Wh / 370*122*76 2,7 PowerPack 500 Performance Line Rack anthracite / 0275.007.532 / 36Vx40, 13,4 Ah, 500 Wh/ PowerPack 500 Active US Frame Platinum / 0275.007.533 / 36Vx40, 13,4 Ah, 500 Wh / 320*90*90 PowerPack 500 Performance US Frame Anthracite / 0275.007.534 / 36Vx40, 13,4 Ah, 500 Wh / 320*90*90 PowerPack 500 Active US Rack Type Platinum / 0275.007.535 / 36Vx40, 13,4 Ah, 500 Wh / 370*122*76 PowerPack 500 Performance US Rack Type Anthracite / 0275.007.536 / 36Vx40, 13,4 Ah, 500 Wh/ PowerPack 400 Active US Frame Platinum / 0275.007.538 / 36Vx40, 11 Ah, 400 Wh / 320*90*90 2,4 PowerPack 300 Active Line Frame Platinum / 0275.007.547 / 36Vx40, 8,2 Ah, 300Wh / 320*90*90 2,4 PowerPack 300 Performance Line Frame Anthracite / 0275.007.548 / 36Vx40, 8,2 Ah, 300Wh / 320*90*90 PowerPack 300 Active Line Frame Anthracite Japan / 0275.007.549 / 36Vx40, 8,2 Ah, 300Wh / 320*90*90 PowerTube 500 Horizontal Black / 0275.007.539 / 36Vx40, 13,4 Ah, 500 Wh / 360*84*652,8 PowerTube 500 Vertical Black / 0275.007.540 / 36Vx40, 13,4 Ah, 500 Wh / 360*84*65 PowerTube 500 Horizontal Black US / 0275.007.541 / 36Vx40, 13,4 Ah, 500 Wh / 360*84*65 2,8 PowerTube 500 Vertical Black US / 0275.007.542 / 36Vx40, 13,4 Ah, 500 Wh / 360*84*65 2,8 1.2. Relevant identified uses of the substance or mixture and uses advised against Use of the substance/mixture Not applicable. 1.3. Details of the supplier of the safety data sheet Company name: Robert Bosch GmbH Automotive Electronics Revision No: 1,2 GB - EN Revision date: 16.03.2017 <<>> Safety Data Sheet according to Regulation (EC) No 1907/2006 Robert Bosch GmbH Revision date: 16.03.2017 Revision No 1,2 Batterypack - Dangerous Good according to UN3480 11728-0001 Street: Place: Telephone: Responsible Department: 1.4. Emergency telephone number: Gerhard-Kindler-Str.3 D-72770 Reutlingen +49 (0)7121 7666000 Responsible for the safety data sheet: sds@gbk-ingelheim.de +49 (0) 6132 / 84463 (GBK GmbH) SECTION 2: Hazards identification 2.1. Classification of the substance or mixture Classification according to Directive 67/548/EEC or 1999/45/EC This mixture is not classified as hazardous in accordance with Directive 1999/45/EC. Not applicable Classification according to Regulation (EC) No. 1272/2008 [CLP] This mixture is not classified as hazardous in accordance with Regulation (EC) No. 1272/2008. 2.2. Label elements Additional advice on labelling There is no hazard when the measures for handling and storage are followed . 2.3. Other hazards In case of electrolyte leakage: According to concentration, aqueous solution causes irritations or burns of eyes, skin and mucous membranes. In case of cell damage, possible release of dangerous substances and a flammable gas mixture. SECTION 3: Composition/information on ingredients 3.2. Mixtures Chemical characterization Kathode: Litium-Metall Oxide (active material) Polyvinyldiene Fluoride (Binder) Graphite (conductive material) Aluminium Foil Anode: Carbon(active material) Polyvinyldiene Fluoride (Binder) Cooper Foil Electrolyte: Organic solvent (non aqueous liquid) Silicic acid, lithium salt Further Information Because of the cell structure the dangerous ingredients will not be available if used properly. SECTION 4: First aid measures 4.1. Description of first aid measures General information The following first aid measures are required only in case of exposure to interior battery components after damage of the external battery casing. Undamaged, closed cells do not represent a danger to the health. After inhalation Ensure of fresh air. Consult a physician. After contact with skin In case of contact with skin wash off immediately with soap and water. Revision No 1,2 GB- EN Revision date: 16.03.2017 <<>> Safety Data Sheet according to Regulation (EC) No 1907/2006 Robert Bosch GmbH Revision date: 16.03.2017 Revision No: 1,2 Batterypack - Dangerous Good according to UN3480 11728-0001 (@) BOSCH Consult a physician. After contact with eyes Rinse immediately with plenty of water, also under the eyelids, for at least 15 minutes. Seek medical treatment by eye specialist. After ingestion Drink plenty of water. Do not induce vomiting . Call a physician immediately. 4.2. Most important symptoms and effects, both acute and delayed In case of electrolyte leakage: According to concentration, aqueous solution causes irritations or burns of eyes, skin and mucous membranes. 4.3. Indication of any immediate medical attention and special treatment needed Treat symptoms. SECTION 5: Firefighting measures 5.1. Extinguishing media Suitable extinguishing media Cold water and dry powder in large amount are applicable. Use metal fire extinction powder or dry sand if only few cells are involved. 5.2. Special hazards arising from the substance or mixture Burning may release the following flue gases such as: carbon monoxide and carbon dioxide 5.3. Advice for firefighters Wear self-contained breathing apparatus and protective suit. Additional information If possible, remove cell(s) from fire fighting area. If heated above 125°C, cell(s) can explode/vent. Cell is not flammable but internal organic material will burn if the cell is incinerated. SECTION 6: Accidental release measures 6.1. Personal precautions, protective equipment and emergency procedures Use personal protective clothing. Avoid contact with skin, eyes and clothing . Avoid breathing fume and gas. 6.2. Environmental precautions Do not discharge into the drains/surface waters/ground water. 6.3. Methods and material for containment and cleaning up Take up mechanically and send for disposal. 6.4. Reference to other sections Information for disposal see section 13. SECTION 7: Handling and storage 7.1. Precautions for safe handling Advice on safe handling Avoid short circuiting the cell. Avoid mechanical damage of the cell. Do not open or disassemble. Follow the directions. Advice on protection against fire and explosion Keep away from open flames, hot surfaces and sources of ignition. 7.2. Conditions for safe storage, including any incompatibilities Requirements for storage rooms and vessels Store only in original container at cool and aired place. Recommended storage temperature: < 40 °c 7.3. Specific end use(sl No data available. Revision No. 1,2 GB- EN Revision date: 16.03.2017 <<>> Safety Data Sheet according to Regulation (EC) No 1907/2006 Robert Bosch GmbH Revision date: 16.03.2017 Revision No: 1,2 Batterypack - Dangerous Good according to UN3480 11728-0001 (@) BOSCH SECTION 8: Exposure controls/personal protection 8.1. Control parameters Additional advice on limit values During normal charging and discharging there is no release of product. 8.2. Exposure controls Protective and hygiene measures In case of electrolyte leakage: Provide sufficient air exchange and/or exhaust in work rooms. Use personal protective clothing. Avoid contact with skin, eyes and clothing. Avoid breathing fume and gas. Remove all sources of ignition. Eye/face protection In case of electrolyte leakage: Tightly fitting goggles (EN 166). Hand protection In case of electrolyte leakage: Rubber gloves Respiratory protection In case of electrolyte leakage: Use protective face mask (EN 149). SECTION 9: Physical and chemical properties 9.1. Information on basic physical and chemical properties Physical state: Solid Colour: Various Odour: Odourless Changes in the physical state 9.2. Other information No data available. SECTION 10: Stability and reactivity 10.1. Reactivity No data available. 10.2. Chemical stability No data available. 10.3. Possibility of hazardous reactions Electrolyte and electrodes may react with water or moisture. 10.4. Conditions to avoid Keep away from open flames, hot surfaces and sources of ignition. Do not puncture, crush or incinerate. Avoid temperatures above 60°C. 10.5. Incompatible materials No materials to be especially mentioned. 10.6. Hazardous decomposition products No data available. Further information No decomposition if stored and applied as directed. SECTION 11 : Toxicological information Revision No 1,2 GB-EN Revision date: 16.03.2017 <<>> Safety Data Sheet according to Regulation (EC) No 1907/2006 Robert Bosch GmbH Revision date: 16.03.2017 Revision No: 1,2 Batterypack - Dangerous Good according to UN3480 11728-0001 r§) BOSCH 11 .1. Information on toxicological effects Acute toxicity Based on available data, the classification criteria are not met. LD50/oral/rat 2000 mg/kg (Electrolyte) Irritation and corrosivity Based on available data, the classification criteria are not met. In case of electrolyte leakage: According to concentration, aqueous solution causes irritations or burns of eyes, skin and mucous membranes. Sensitising effects Based on available data, the classification criteria are not met. In case of electrolyte leakage: May cause sensitization by skin contact. STOT-single exposure Based on available data, the classification criteria are not met. Severe effects after repeated or prolon. ged exposure Based on available data, the classification criteria are not met. Carcinogenic/mutagenic/toxic effects for reproduction Based on available data, the classification criteria are not met. Aspiration hazard Based on available data, the classification criteria are not met. Practical experience Other observations become known. If appropriately handled and if in accordance with the general hygienic rules, no damages to health have SECTION 12: Ecological information 12.1. Toxicity No data available. 12.2. Persistence and degradability No data available. 12.3. Bioaccumulative potential No data available. 12.4. Mobility in soil No data available. 12.5. Results of PBT and vPvB assessment No data available. 12.6. Other adverse effects No data available. Further information Ecological injuries are not known or expected under normal use. Do not flush into surface water or sanitary sewer system. SECTION 13: Disposal considerations 13.1. Waste treatment methods Waste disposal number of waste from residues/unused products 160605 WASTES NOT OTHERWISE SPECIFIED IN THE LIST; batteries and accumulators; other batteries and accumulators Contaminated packaging Disposal in accordance with local regulations. SECTION 14: Transport information Land transport (ADR/RID) Revision No 1,2 GB-EN Revision date· 16.03.2017 <<>> Safety Data Sheet according to Regulation (EC) No 1907/2006 Robert Bosch GmbH Revision date: 16.03.2017 Revision No: 1,2 Batterypack - Dangerous Good according to UN3480 11728-0001 ~ij) BOSCH 14.1. UN number: 14.2. UN proper shipping name: 14.3. Transport hazard class{es): 14.4. Packing group: Hazard label: UN 3480 LITHIUM ION BATTERIES 9 Classification code: Special Provisions: Limited quantity: Transport category: Tunnel restriction code: Inland waterways transport (ADN) 14.1. UN number: 14.2. UN proper shipping name: 14.3. Transport hazard class(es): 14.4. Packing group: Hazard label: Classification code: Special Provisions: Limited quantity: Marine transport (IMDG) 14.1. UN number: 14.2. UN proper shipping name: 14.3. Transport hazard class(es): 14.4. Packing group: Hazard label: Special Provisions: Limited quantity: EmS: Air transport (ICAO-TI/IATA-DGR) 14.1. UN number: 14.2. UN proper shipping name: 14.3. Transport hazard class(es): 14.4. Packing group: Hazard label: M4 0 2 E 188 230 310 348 376 377 636 UN 3480 Lithium-ion battery 9 9A ., ll'th ... ~- M4 0 188 230 310 348 376 377 636 UN 3480 LITHIUM ION BATTERIES 9 9A ., , I I 11~ . ... ~ 188, 230, 310, 348, 376, 377 0 F-A, S-1 UN 3480 LITHIUM ION BATTERIES 9 Special Provisions: Limited quantity Passenger: IATA-packing instructions - Passenger IATA-max. quantity - Passenger: Rev1s1 on No: 1,2 A88 A99 A 154 A 164 A 183 A201 A206 A331 Forbidden Forbidden Forbidden GB EN Rev1s1on date: 16.03.2017 <<>> Safety Data Sheet according to Regulation (EC) No 1907/2006 Robert Bosch GmbH Revision date: 16.03.2017 Revision No: 1,2 Batterypack - Dangerous Good according to UN3480 11728-0001 1 @) BOSCH IA TA-packing instructions - Cargo: IATA-max. quantity - Cargo: 14.5. Environmental hazards See 965 See 965 ENVIRONMENTALLY HAZARDOUS: no 14.6. Special precautions for user No specific precautions required . 14.7. Transport in bulk according to Annex II of Marpol and the IBC Code The transport takes place only in approved and appropriate packaging. SECTION 15: Regulatory information 15.1. Safety. health and environmental regulations/legislation specific for the substance or mixture National regulatory information Additional information Note: This product is an "article" and is not an object that is required to issue Safety Data Sheets (SOS) by regulations concerning chemical substances. This SOS voluntarily offers helpful information for your safe handling and environmental care. 15.2. Chemical safety assessment Chemical safety assessments for substances in this mixture were not carried out. SECTION 16: Other information Changes Changes in chapter: 9 Abbreviations and acronyms ADR = Accord europeen relatif au transport international des marchandises Dangereuses par Route RID = Reglement concernant le transport international ferroviaire de marchandises dangereuses AON = Accord europeen relatif au transport international des marchandises dangereuses par voie de navigation interieure IMDG = International Maritime Code for Dangerous Goods IATA/ICAO = International Air Transport Association/ International Civil Aviation Organization MARPOL = International Convention for the Prevention of Pollution from Ships DOT = Department of Transportation TOG = Transport of Dangerous Goods GHS = Globally Harmonized System of Classification and Labelling of Chemicals REACH = Registration, Evaluation, Authorization and Restriction of Chemicals CAS = Chemical Abstract Service EN = European norm ISO = International Organization for Standardization DIN = Deutsche lndustrie Norm PBT = Persistent Bioaccumulative and Toxic vPvB = Very Persistent and very Bio-accumulative LO = Lethal dose LC = Lethal concentration EC = Effect concentration IC = Median immobilisation concentration or median inhibitory concentration Further Information Data of items 4 to 8, as well as 10 to 12, do partly not refer to the use and the regular employing of the product (in this sense consult information on use and on product), but to liberation of major amounts in case of accidents and irregularities. The information describes exclusively the safety requirements for the product(s) and is based on the present level of our knowledge. This data does not constitute a guarantee for the characteristics of the product(s) as defined by the legal warranty regulations. (n.a. = not applicable; n.d. = not determined) (The data for the hazardous ingredients were taken respectively from the last version of the sub-contractor's safety data sheet.) Revision No: 1,2 GB-EN Revision date· 16.03 2017 - **truncated:** false - **body characters:** 25974