# Daly's Wood Finishing Products — Hazardous Materials Safety Interpretation - **operation:** document - **citation:** 25-0011 - **title:** Daly's Wood Finishing Products — Hazardous Materials Safety Interpretation - **source type:** guidance - **agency:** Pipeline and Hazardous Materials Safety Administration - **status:** guidance - **official:** true - **published on:** 2025-07-24 - **effective on:** Not available - **summary:** 25-0011 response to Daly's Wood Finishing Products concerning 173.21, 176.83. - **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-interpretation-25-0011.json - **markdown:** https://regulus.evalyn.ai/document/phmsa-interpretation-25-0011.md - **app url:** https://regulus.evalyn.ai/document/phmsa-interpretation-25-0011 - **source url:** https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/2025-07/250011.pdf **body:** <<>> 1200 New Jersey Avenue, SE Washington, DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration July 24, 2025 Courtney Ostbye Director of Operations Daly’s Wood Finishing Products A Division of Farwest Paint Mfg. Co 4522 S. 133rd St Tukwila, WA 98168 Reference No. 25-0011 Dear Ms. Ostbye: This letter is in response to your January 21, 2025 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the segregation requirements of a two-component wood bleach solution. You state that your company manufactures and markets a wood bleach solution comprising both “UN1824, Sodium hydroxide solution, 8, II”— which is referred to as bleach solution A—and “UN2014, Hydrogen peroxide, aqueous solution, 5.1 (8), II”—which is referred to as bleach solution B. You state that each component is packaged individually in a pint, quart, or gallon plastic bottle. You further state the pint and quart-sized plastic bottles are enclosed together in the same industrial polyethylene bags, while the gallon-sized bottles are packaged separately in polyethylene bags; and then, in both cases, the components are packaged together in United Nations (UN) fiberboard boxes. Lastly, you state that these components are designed to be mixed by the end-user (i.e., customer) and pose no risk of combustion, evolution of considerable heat, evolution of flammable or poisonous gases or vapors, or the formation of corrosive or unstable substances when mixed. You ask does the segregation requirements in § 176.83(b) of the HMR and Chapter 7.2 of the International Maritime Dangerous Goods (IMDG) Code apply to the components of this kit? You are correct in that the segregation requirements in the table in § 176.83(b) indicate that these two components would not be allowed in the same shipping container, and therefore they would not be allowed in the same outer packaging. However, one of the provisions for the segregation requirements is found in § 176.83(a)(4)(ii), where it states that segregation is not required between hazardous materials of different classes which comprise a group of substances that do not react dangerously with each other. That provision goes on to list some materials that are grouped by compatibility. It should be noted that there may be additional groups of materials that are compatible and do not react dangerously with each other that are not listed in paragraph <<>> (a)(4)(ii)(A) through (C), even when segregation applies in accordance with § 176.83(b). The IMDG Code contains a similar provision in Section 7.2.6.3.2. Additionally, all packagings of hazardous materials must comply with § 173.21(e), which states that it is forbidden to offer for transportation “a material in the same packaging, freight container, or overpack with another material, the mixing of which is likely to cause a dangerous evolution of heat, or flammable or poisonous gases or vapors, or to produce corrosive materials.” 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 <<>> Larson 25-0011 From: INFOCNTR (PHMSA) To: Dodd, Alice (PHMSA) Subject: FW: Request for Letter of Interpretation / Exemption Date: Tuesday, January 28, 2025 4:47:46 PM Attachments: USDOT Exemption Request Letter.pdf _A_BLEACH.pdf _B_BLEACH.pdf Wood Kote Lite-N-Up Part A - SDS.PDF PH MSA 98-0509.pdf Wood Kote WB801 SDS.pdf Wood Kote WB802 SDS.pdf Importance: High Hi Alice, I’m resending this interpretation request email in case it was missed. Thanks From: INFOCNTR (PHMSA) Sent: Wednesday, January 22, 2025 5:00 PM To: Hazmat Interps Subject: FW: Request for Letter of Interpretation / Exemption Importance: High Hello Hazmat Interps, Please see the attached request for letter of interpretation and other attachments. Thanks, Jonathon From: Courtney Ostbye Sent: Tuesday, January 21, 2025 4:48 PM To: INFOCNTR (PHMSA) Subject: Request for Letter of Interpretation / Exemption Importance: High You don't often get email from courtney@dalyswoodfinishes.com. Learn why this is important CAUTION: This email originated from outside of the Department of Transportation (DOT). Do not click on links or open attachments unless you recognize the sender and know the content is safe. Thank you for talking with me this afternoon. As you know, we are seeking an exemption to ship our A&B Wood Bleach Solution together in the same box. Our competitors have obtained letters of interpretation that have allowed them to ship <<>> their items together and sell nationally and internationally. Attached you will find a letter from me for a letter of interpretation/exemption, as well as the following supporting documents: Daly’s Bleach Solution “A” SDS Daly’s Bleach Solution “B” SDS Daly’s Wood Bleach Specification Sheet PH MSA 98-0509 Wood Kote WB801 “A” SDS Wood Kote WB802 “B” SDS Best Regards, Courtney Ostbye Director of Operations Daly's Wood Finishing Products A Division of Farwest Paint Mfg. Co. (206) 244-8844 ext 114 4522 S 133rd St - Tukwila, WA - 98168 <<>> DALYS WOOD FINISHING PRODUCTS A DIVISION OF FARWEST PAINT MFG. CO. Daly's Wood Finishing Products A Division of Farwest Paint Mfg Co 4522 S 133d St Tukwila, WA 98168 January 21, 2025 Office of Hazardous Materials Standards US Department of Transportation 1200 New Jersey Ave SE Washington, DC 20590 RE: Request for Letter of Interpretation/Exemption To Whom It May Concern: We manufacture and market a two component Wood Bleach Solution. The components of our Wood Bleach are part "A", a Sodium Hydroxide Solution and part "B", a Hydrogen Peroxide Aqueous Solution. Each component is packaged in pint, quart and gallon HDPE, high density polyethylene, bottles. All bottles are HIS with Vented CRC caps and then enclosed in 2mil industrial poly bags. The pint and quart bottles are enclosed together and the gallon kits are enclosed separately. All components are then packaged in UN specified heavy weight fiberboard cartons. Should the two components leak and combine they pose no risk of reacting dangerously with each other. Our A&B Wood Bleach Solution is specifically made to mix together, through proprietary formulation, and does not cause any external reaction when mixed together. Our two part Wood Bleach Solution will not cause combustion, evolution of considerable heat, evolution of flammable or poisonous gases or vapors, or the formation of corrosive or unstable substances. The two components combined are less dangerous than each component individually. In fact, our Bleach Solution "B" has a subsidiary hazmat number of 8 which is the same as the Bleach Solution "A". Attached you will find the following SDS Sheets: • Bleach Solution "A" (Product Code 17010) • Bleach Solution "B" (Product Code 17110) I have also attached a letter of interpretation given to our direct competitor Wood Kote. I have attached their SDS sheets as well and you will see they are nearly identical. Our concern is the same as Wood Kote's, addressed in your April 17, 1998 letter. We want to be able to make domestic and international freight and marine shipments with our two components packaged together. 4522 S. 133rd ST., TUKWILA, WA 98168 ph 206.244.8844 fx 206.246.7691 toll-free 800.727.9694 w DALYSWOODFINISHES.COM <<>> DALYS WOOD FINISHING PRODUCTS A DIVISION OF FARWEST PAINT MFG. CO. We would like to have a clarification addressed to Daly's Wood Finishing Products & Farwest Paint Mfg Co directly to present to shipping authorities. We would like to request for the USDOT to provide a clarification letter which states that our Wood Bleach Solution components are compatible for shipment together and therefore the segregation requirements enumerated in the IMDG Code page 0129 15.1.16 and 49 CFR 176.83(b) in accordance with the hazardous material segregation table, do not apply to our A&B Wood Bleach Solution. If any more information is required for this request or you have any questions please reach out directly by email: Courtney@dalyswoodfinishes.com; or by phone: (206) 244-8844 ext 114. Thank you for your time and consideration in this matter. Best Regards, Courtney Ostbye Director of Operations Daly's Wood Finishing Products A Division of Farwest Paint Mfg Co 4522 S. 133rd ST., TUKWILA, WA 98168 ph 206.244.8844 fx 206.246.7691 toll-free 800.727.9694 w DALYSWOODFINISHES.COM <<>> SAFETY DATA SHEET WOOD KOTE PRODUCTS INC. www.woodkote.com Section 1: Product and Company Identification Product Name: Lite-N-Up Part "B" (Wood Bleach) Product Code: 802B WOOD KOTE PRODUCTS INC. 8000 NE 14th Place TEL: 503-285-8371 Portland, Oregon 97211 800-843-7666 (Toll Free USA & Canada) USA FAX: 503-285-8374 E-MAIL: info@woodkote.com EMERGENCY CONTACT INFOTRAC (Transportation): 800-535-5053 Product Use: Intended for professional use only. Wood Bleach component intended to be combined in equal proportions with Lite-N-Up Part "A" (Product Code 801A) Section 2: Hazards Identification GHS Ratings: Skin corrosive 1A Destruction of dermal tissue: exposure < 3 min. Observation < Eye corrosive 1 1 hour, visible necrosis in at least one animal. Serious eye damage: irreversible damage 21 days after Reproductive toxin 1B exposure. Draize score: Corneal opacity >= 3, Iritis > 1.5. Presumed, based on experimental animals. GHS Hazards H290 May be corrosive to metals. H302 Harmful if swallowed. H314 Causes severe skin burns and eye damage. GHS Precautions P260 P273 P262 Do not get in eyes, on skin, or on clothing. Do not breathe mist/vapours/spray. Avoid release to the environment. P281 P280 Wear protective gloves/protective clothing/eye protection/face protection. P301+P330+P331 P391 Use personal protective equipment as required. Collect spillage. IF SWALLOWED: Rinse mouth. Do NOT induce vomiting P303+P361+P353 IF ON SKIN (or hair): Remove/Take off immediately all contaminated clothing. Rinse skin with water/shower P304+P340 IF INHALED: Remove victim to fresh air and keep at rest in a position comfortable for P305+P351+P338 IF IN EYES: Rinse continuously with water for several minutes. Remove contact breathing P308+P313 lenses if present and easy to do - continue rinsing IF exposed or concerned: Get medical advice/attention P404 Store in a closed container. P501WK If spilled, contain spilled material and dispose of contaminated absorbent, container and unused contents in accordance with local, state and federal regulations. Avoid release to the environment. SDS for: 802B Page 1 of 5 <<>> Signal Word: Danger CORROSIVE Section 3: Composition / Information on Ingredients Chemical Name CAS number Weight Concentration % Water 7732-18-5 90.00% - 100.00% Sodium Hydroxide 1310-73-2 1.00% - 5.00% Section 4: First Aid Measures IF INHALED: If breathing is difficult, remove source of exposure or move victim to fresh air and keep at rest in a IF IN EYES: Rinse eyes cautiously with lukewarm, gently flowing water for 15 minutes, while holding the eyelids position comfortable for breathing. If victim is not breathing, call 911 and administer CPR as directed. open. Remove contact lenses, if present and easy to do. Continue rinsing. Take care not to rinse contaminated water into the unaffected eye or onto the face. Get immediate medical attention. IF ON SKIN: Remove contaminated clothing/shoes. Flush skin with water for at least 15 minutes. Follow by washing IF SWALLOWED: If fully conscious, drink as much water as can be tolerated. DO NOT induce vomiting. DO NOT with soap and water. If irritation occurs, get medical attention. Do not reuse clothing until cleaned. neutralize with acidic juices. Get medical attention immediately. Note to Physician: Provide general supportive measures and treat symptomatically. Section 5: Fire Fighting Measures Flash Point: NDA LEL: NDA UEL: NDA FLAMMABILITY: Product is not flammable and will not burn. EXTINGUISHING MEDIA: Use water fog, foam, dry chemical, or CO2. fumes/vapors. Exposure to products of decomposition during a fire may be hazardous. SPECIFIC HAZARDS: In a fire, dried product can decompose at elevated temperatures and may release toxic HAZARDOUS COMBUSTION PRODUCTS: Carbon monoxide and unidentified organic compounds may be formed during combustion. FIRE FIGHTING PROCEDURES: Wear self-contained breathing apparatus and gear when fighting fires involving this material. Although not flammable as supplied, this material is a strong oxidizer and will contribute copious amounts FIRE EQUIPMENT: Do not enter confined fire space without full bunker gear (helmet with face shield, bunker coats, of oxygen during decomposition. gloves and rubber boots), including a positive pressure, NOISH approved, self-contained breathing apparatus Section 6: Accidental Release Measures PERSONAL PRECAUTIONS: Keep unnecessary personnel away. Keep people away from and upwind of spill/leak. appropriate protective equipment and clothing during clean-up. Do not breathe mist or vapor. Do not touch damaged Keep out of low areas. Eliminate all ignition sources (no smoking, flares, sparks or flames in immediate area. Wear containers or spilled material unless wearing appropriate protective clothing. Ventilate closed spaces before entering them. Local authorities should be advised if significant spillages cannot be contained. SMALL SPILLS: Wipe up with absorbent material (e.g. cloth, fleece). Clean surface thoroughly to remove residual contamination. Never return spills to original containers for re-use. LARGE SPILLS: Dike far ahead of liquid spill for later disposal. Keep material out of storm sewers and ditches which lead to waterways. SDS for: 802B Page 2 of 5 <<>> Section 7: Handling and Storage HANDLING: Use caution when combining with Lite-N-Up "A" (Product code 801A). Do not taste or swallow. Avoid contact with eyes, skin and clothing. Wash thoroughly after handling. Keep away from heat, sparks, and flame. Surfaces that are hot may ignite even liquid product in the absence of sparks or flame. Extinguish pilot lights, STORAGE: Keep in original container tightly closed when not in use and stored away in a cool dark area up to one cigarettes and turn off other sources of ignition prior to use and until all vapors are gone. year. COMMENTS: Read label before use. KEEP OUT OF REACH OF CHILDREN! Empty containers, retain product flame, sparks static electricity, or other sources of ignition; they may explode and cause injury or death. residue (liquid and/or vapor). Do not pressurize, cut weld, braze, solder, drill, grind, or expose such containers to heat, Section 8: Exposure Control and Personal Protection Chemical Name / CAS No. OSHA Exposure Limits ACGIH Exposure Limits other Exposure Limits Water NDA NDA NDA 7732-18-5 Sodium Hydroxide PEL: 2mg/m3 CEILING: 2 mg/m3 NIOSH IDLH: 10 mg/m3 1310-73-2 ENGINEERING CONTROLS: Provide explosion-proof general local exhaust ventilation sufficient to keep the airborne reduce environmental contamination. concentration of this product below its exposure limits. Exhaust air may need to be cleaned by scrubbers or filters to VENTILATION: Good general ventilation should be used. Ventilation rates should be matched to conditions. PERSONAL PROTECTIVE EQUIPMENT EYES AND FACE: Wear safety goggles. Maintain eye wash fountain and quick drench facilities in work areas. SKIN: Wear protective gloves. To prevent repeated or prolonged skin contact, wear impervious clothing and boots. regulations found in 29 CFR 1910.134. Use a NIOSH/MSHA approved respirator if exposure limits are exceeded or RESPIRATORY: In case of insufficient ventilation, wear suitable respiratory equipment. Follow the OSHA respirator symptoms are experienced WORK HYGIENIC PRACTICES: Handle in accordance with good industrial hygiene and safety practice. Wash thoroughly with soap and water after handling and before eating, drinking, or using tobacco. Safety shower and eye wash should be available close to work areas. OTHER USE PRECAUTIONS: May be harmful if swallowed. May irritate body tissues. Use with adequate ventilation. Avoid breathing vapor. Do not get in eyes, on skin, on clothing. Wash thoroughly after handling. COMMENTS: Facilities storing or utilizing this material should be equipped with an eyewash facility and a safety shower. for cleaning/maintaining PPE. If no such instructions for washables, use detergent and hot water. Keep and wash PPE CONTAMINATED GEAR: Take off contaminated clothing and wash it before reuse. Follow manufacturer's instructions separately from other laundry. Section 9: Physical and Chemical Properties Autoignition temperature: N/A Decomposition temperature: N/A Grams 0.0 Viscosity: N/A VOC/Coating/Regulatory Appearance: Clear, Colorless Odor: Slightly pungent Vapor Pressure: 0 mm Hg 30 C Odor threshold: 3.88 Vapor Density: >1 PH >13 Melting point: N/A Freezing point: N/A Solubility: Complete Boiling range: 100°C Flash point: NDA Evaporation rate: >1 (n-Butyl Acetate=1) SDS for: 802B Page 3 of 5 <<>> Section 10: Stability and Reactivity Stability: Under normal conditions: STABLE Incompatibilities: Incompatible with acids, halogenated compounds, aluminum, brass, bronze, copper, lead, tin, and zinc. Hazardous decomposition: Contact with certain metals may produce hydrogen gas. Hazardous polymerization will not occur. Section 11: Toxicological Information Component Toxicity 1310-73-2 Sodium Hydroxide Oral LD50: 300 mg/kg (Rat) Dermal LD50: 500 mg/L (Rabbit) PRIMARY ROUTES OF ENTRY Inhalation, skin contact, eye contact, ingestion. Target Organs: Eyes, lungs, reproductive system, cholinesterase, respiratory system. Effects of Overexposure Inhalation Effects from inhalation of dust or mist vary from mild irritation to serious damage of the upper respiratory tract, depending on severity of exposure. Symptoms may include sneezing, sore throat or runny nose. Severe pneumonitis may occur. Ingestion tissue and death may result. Symptoms may include bleeding, vomiting, diarrhea, fall Swallowing may cause severe burns of mouth, throat, and stomach. Severe scarring of in blood pressure. Damage may appears days after exposure. Skin Contact Contact with skin can cause irritation or severe burns and scarring with greater exposures. Eye Contact result in permanent impairment of vision, even blindness. Causes irritation of eyes, and with greater exposures it can cause burns that may Chronic Prolonged contact with dilute solutions or dust has a destructive effect upon tissue. Section 12: Ecological Information Component Ecotoxicity Sodium Hydroxide Invertebrate: 48 hr EC50 Daphnia magna: 34.59 - 47.13 mg/L Fish: 96 hr LC50 Western Mosquitofish: 125 mg/L; 48 hr LC50 Bluegill: 99 mg/L Section 13: Disposal Considerations DISPOSAL: If spilled, contain spilled material and dispose of contaminated absorbent, container and unused contents in accordance with local, state and federal regulations. Avoid release to the environment. Section 14: Transport Information Agency Proper Shipping Name UN Number Packing Group Hazard Class DOT Sodium Hydroxide, Solution UN1824 8 IATA Sodium Hydroxide, Solution UN1824 8 IMDG Sodium Hydroxide, Solution UN1824 8 SDS for: 802B Page 4 of 5 <<>> 6#+, '+' 2 2I; 1 7C8# 77. +#';#. !+" &28 C' 7 . %!+ 1 72" &28 C. #, ./.(C?7'+.CC?! +8.CC?6 ;!0 77#-!%$% <'<';9 D''9 )*&,*B&C %,**B%C ,98 . &D%)#+ 4+ A EF0,0) C AF%'%% . A 1 798 F4' (F&!# .F' & 4&# 2 797 ;97 79;96 "">> SAFETY DATA SHEET WOOD KOTE PRODUCTS INC. www.woodkote.com Section 1: Product and Company Identification Product Name: Lite-N-Up Part "A" (Wood Bleach) Product Code: 801A WOOD KOTE PRODUCTS INC. 8000 NE 14th Place TEL: 503-285-8371 USA Portland, Oregon 97211 FAX: 503-285-8374 800-843-7666 (Toll Free USA & Canada) E-MAIL: info@woodkote.com EMERGENCY CONTACT INFOTRAC (Transportation): 800-535-5053 Product Use: Intended for professional use only. Wood Bleach component intended to be combined in equal proportions with Lite-N-Up Part "B" (Product Code 802B) Section 2: Hazards Identification GHS Ratings: Oxidizing liquid 2 Dermal Toxicity Oral Toxicity Acute Tox. 4 Oxidizing liquid class 2 Acute Tox. 4 Oral>300+<=2000mg/kg Skin corrosive 2 Dermal>1000+<=2000mg/kg Reversible adverse effects in dermal tissue. Draize score: >= Eye corrosive 1 2.3 ‹ 4.0 or persistent inflammation. Serious eye damage: irreversible damage 21 days after Organ toxin single exposure 3 exposure. Draize score: Corneal opacity >= 3, Iritis > 1.5. Transient target organ effects- Narcotic effects- Respiratory Organ toxin repeated 2 tract irritation. Presumed to be harmful to human health- Animal studies with exposure significant toxic effects relevant to humans at generally moderate exposure (guidance)- Human evidence in exceptional GHS Hazards cases. H302 H271 Harmful if swallowed. May cause fire or explosion; strong oxidizer. H315 H312 Harmful in contact with skin. H318 Causes skin irritation. Causes serious eye damage. H335 May cause respiratory irritation. H373 May cause damage to organs through prolonged or repeated exposure. GHS Precautions P210 P220 Keep away from heat/sparks/open flames/hot surfaces - No smoking. P221 Keep/Store away from clothing/combustible materials. P260 Take any precaution to avoid mixin with combustibles. Do not breathe mist/vapours/spray. P280 Wear protective gloves/protective clothing/eye protection/face protection. P301+P312 P304+P340 P302+P352 IF SWALLOWED: Call a POISON CENTER or doctor/physician if you feel unwell IF ON SKIN: Wash with soap and water IF INHALED: Remove victim to fresh air and keep at rest in a position comfortable for P305+P351+P338 IF IN EYES: Rinse continuously with water for several minutes. Remove contact breathing lenses if present and easy to do - continue rinsing SDS for: 801A Page 1 of 6 <<>> P332+P313 If skin irritation occurs: Get medical advice/attention P403 P370+P378 In case of fire: Use water fog, "alcohol" foam, dry chemical, or CO2. P405 Store locked up. Store in a well ventilated place. P420 P501WK Store away from other materials. If spilled, contain spilled material and dispose of contaminated absorbent, container and unused contents in accordance with local, state and federal regulations. Avoid release to the environment. Signal Word: Danger STRONG OXIDIZER Section 3: Composition / Information on Ingredients Chemical Name CAS number Weight Concentration % Water 7732-18-5 70.00% - 80.00% Hydrogen Peroxide 7722-84-1 20.00% - 30.00% Section 4: First Aid Measures IF INHALED: If breathing is difficult, remove victim to fresh air and keep at rest in a position comfortable for breathing. Call a POISON CENTER or doctor/physician. IF IN EYES: Immediately flush eyes with plenty of water for at least 15 minutes. Remove contact lenses, if present and easy to do. Get medical attention if irritation develops and persists. IF ON SKIN: Take off immediately all contaminated clothing. Rinse skin with water/shower. Get medical attention if irritation develops and persist. IF SWALLOWED: DO NOT INDUCE VOMITING. Do not attempt to give anything by mouth to an unconscious person. If vomiting occurs spontaneously, keep head below hips to prevent aspiration of liquid into the lungs. Get medical attention. Note to Physician: Provide general supportive measures and treat symptomatically. Keep victim warm. Keep under observation. Symptoms may be delayed Section 5: Fire Fighting Measures Flash Point: NDA LEL: NDA UEL: NDA EXTINGUISHING MEDIA: Use water fog, foam, dry chemical, or CO2. Do not use water jet as an extinguisher, as this will spread the fire. HAZARDOUS COMBUSTION PRODUCTS: Greatly increases the burning rate of combustible materials. Containers EXPLOSION HAZARDS: May intensify fire. Strong oxidizer! Contact with combustible material may cause fire. may explode when heated. During fire, gases hazardous to health may be formed. FIRE FIGHTING PROCEDURES: Wear self-contained breathing apparatus and gear when fighting fires involving this material. Although not flammable as supplied, this material is a strong oxidizer and will contribute copious amounts FIRE EQUIPMENT: Do not enter confined fire space without full bunker gear (helmet with face shield, bunker coats, of oxygen during decomposition. gloves and rubber boots), including a positive pressure, NOISH approved, self-contained breathing apparatus. SDS for: 801A Page 2 of 6 <<>> Section 6: Accidental Release Measures PERSONAL PRECAUTIONS: Keep unnecessary personnel away. Keep people away from and upwind of spill/leak. appropriate protective equipment and clothing during clean-up. Do not breathe mist or vapor. Do not touch damage Keep out of low areas. Eliminate all ignition sources (no smoking, flares, sparks or flames in immediate area. Weal containers or spilled material unless wearing appropriate protective clothing. Ventilate closed spaces before entering them. Local authorities should be advised if significant spillages cannot be contained. SMALL SPILLS: Absorb with earth, sand or other non-combustible material and transfer to containers for later disposal. Wipe up with absorbent material (e.g. cloth, fleece). Clean surface thoroughly to remove residual contamination. Never return spills to original containers for re-use. LARGE SPILLS: Stop the flow of the material, if this is without risk. Dike the spilled material, where this is possible. up the product and place into a container for later disposal. Use water spray to reduce vapors or divert vapor cloud Cover with plastic sheet to prevent spreading. Use a non-combustible material like vermiculite, sand or earth to soak dritt. Prevent entry into waterways, sewer, basements or confined areas. Following product recovery, flush area with water. Section 7: Handling and Storage HANDLING: PREVENT/ KEEP FROM FREEZING. Do not taste or swallow. Avoid contact with eyes, skin and even liquid product in the absence of sparks or flame. Extinguish pilot lights, cigarettes and turn off other sources of clothing. Wash thoroughly after handling. Keep away from heat, sparks, and flame. Surfaces that are hot may ignite STORAGE: Keep in original container tightly closed when not in use and stored away in a cool dark area up to one ignition prior to use and until all vapors are gone. year. COMMENTS: Read label before use. KEEP OUT OF REACH OF CHILDREN! Empty containers, retain product flame, sparks static electricity, or other sources of ignition; they may explode and cause injury or death. residue (liquid and/or vapor). Do not pressurize, cut weld, braze, solder, drill, grind, or expose such containers to heat, Section 8: Exposure Control and Personal Protection Chemical Name / CAS No. OSHA Exposure Limits ACGI Exposure Limits Other Exposure Limits Water NDA NDA NDA 7732-18-5 Hydrogen Peroxide TWA 1 ppm (1.4 mg/m3) TLV: 1 ppm NDA 7722-84-1 CEIL: 2 mg/m3 ENGINEERING CONTROLS: Provide explosion-proof general local exhaust ventilation sufficient to keep the airborne concentration of this product below its exposure limits. Exhaust air may need to be cleaned by scrubbers or filters to reduce environmental contamination. VENTILATION: Good general ventilation should be used. Ventilation rates should be matched to conditions. PERSONAL PROTECTIVE EQUIPMENT EYES AND FACE: Wear safety goggles. Maintain eye wash fountain and quick drench facilities in work areas. RESPIRATORY: In case of insufficient ventilation, wear suitable respiratory equipment. Follow the OSHA respirator SKIN: Wear protective gloves. To prevent repeated or prolonged skin contact, wear impervious clothing and boots. regulations found in 29 CFR 1910.134. Use a NIOSH/MSHA approved respirator if exposure limits are exceeded or symptoms are experienced. WORK HYGIENIC PRACTICES: Handle in accordance with good industrial hygiene and safety practice. Wash thoroughly with soap and water after handling and before eating, drinking, or using tobacco. Safety shower and eye wash should be available close to work areas. OTHER USE PRECAUTIONS: May be harmful if swallowed. May irritate body tissues. Use with adequate ventilation. Avoid breathing vapor. Do not get in eyes, on skin, on clothing. Wash thoroughly after handling. COMMENTS: Facilities storing or utilizing this material should be equipped with an eyewash facility and a safety shower. for cleaning/maintaining PPE. If no such instructions for washables, use detergent and hot water. Keep and wash PPE CONTAMINATED GEAR: Take off contaminated clothing and wash it before reuse. Follow manufacturer's instructions separately from other laundry. SDS for: 801A Page 3 of 6 <<>> Section 9: Physical and Chemical Properties Vapor Pressure: 0 mm Hg 30 C Vapor Density: >1 PH 2.4-3.4 Freezing point: -28 °F (-33.3 °C) Solubility: Complete Boiling range: 244.1 °F (117.84 °C) Flash point: N/A Evaporation rate: >1 (n-Butyl Acetate=1) Autoignition temperature: N/A Decomposition temperature: N/A VOC/Coating/Regulatory Grams 0.0 Viscosity: 0.890 cP at 25 °C Appearance: Clear, Colorless Odor: Slightly Sharp / Pungent Section 10: Stability and Reactivity Stability: Under normal conditions: STABLE Incompatibilities: Strong oxidizers. Decomposes slowly to release oxygen. Unstable when heated or contaminated with heavy metals, reducing agents, rust, dirt or organic materials. Stability is reduced when pH is above 4.0. Hazardous decomposition: Hazardous polymerization will not occur. Oxygen, hydrogen gas, water, heat, steam. Section 11: Toxicological Information Mixture Toxicity Oral Toxicity LD50: 2,934mg/kg Component Toxicity 7722-84-1 Hydrogen Peroxide Oral LD50: 1,518 mg/kg (Rat) Dermal LD50: 4,060 mg/kg (Rat) PRIMARY ROUTES OF ENTRY Inhalation, skin contact, eye contact, ingestion. Target Organs: Eyes, lungs, respiratory system. Effects of Overexposure Eyes Contact with liquid is corrosive to the eyes and causes severe burns. Contact with the eyes may cause corneal damage. Skin Causes severe skin irritation and possible burns. May cause discoloration, erythema (redness), swelling, and the formation of papules and vesicles (blisters). Ingestion Causes gastrointestinal irritation with nausea, vomiting and diarrhea. Causes gastrointestinal tract burns. May cause vascular collapse and damage. May cause damage to the red blood cells. May cause difficulty in swallowing, stomach distension, possible cerebral swelling and death. Ingestion may result in irritation of the Inhalation esophagus, bleeding of the stomach and ulcer formation. Causes chemical burns to the respiratory tract. May cause ulceration of nasal tissue, insomnia, nervous tremors with numb extremities, chemical pneumonia, acute lung damage and delayed pulmonary edema. unconsciousness, and death. At high concentrations, respiratory effects may include Chronic Prolonged or repeated skin contact may cause dermatitis. Laboratory experiments have resulted in mutagenic effects. Repeated contact may cause corneal damage. SDS for: 801A Page 4 of 6 <<>> Section 12: Ecological Information Component Ecotoxicity Hydrogen Peroxide Fish: Fathead Minnow: LC50 = 16.4 mg/L; 96 Hr; Fresh water Fish: Carp: LC50 = 42 mg/L; 48 Hr; Unspecified Water flea Daphnia: EC50 = 2.4 mg/L; 48 Hr; Fresh water Fish: Fathead Minnow: NOEC = 5 mg/L; 96 Hr; Fresh water Fish: Channel catfish: LC50 = 37.4 mg/L; 96 Hr; Fresh water Section 13: Disposal Considerations in accordance with local, state and federal regulations. Avoid release to the environment. DISPOSAL: If spilled, contain spilled material and dispose of contaminated absorbent, container and unused contents Section 14: Transport Information Agency DOT Proper Shipping Name UN Number Packing Group Hydrogen Peroxide, Aqueous Solution UN2014 Hazard Class 5.1(8) IATA-DR Hydrogen Peroxide, Aqueous Solution Oxidizer, Corrosive UN2014 5.1 (8) IMDG Hydrogen Peroxide, Aqueous Solution Oxidizer, Corrosive UN2014 5.1 (8) Oxidizer, Corrosive Section 15: Regulatory Information ACGIH (American Conference of Governmental Industrial Hygienists) TWA (Time-Weighted Average) NIOSH (National Institute for Occupational Safety and Health) OSHA (Occupational Safety and Health Administration) US Federal regulations: This product is a "Hazardous Chemical" as defined by OSHA Hazard Communication Standard, 29 CFR 1910.1200. Not listed. TSCA Section 12 (b) Export Notification (40 CFR 302.4): SARA 304 Emergency release notification: HYDROGEN PEROXIDE (H202) (CAS 7722-84-1) 1000 Lbs. US. California Proposition 65: California Safe Drinking Water and Toxic Enforcement Act of 1986 (Proposition 65): This material is not known to contain any chemicals currently listed as carcinogens or reproductive toxins. Country: Regulation Canada WHMIS (Workplace Hazardous Materials Information System) SDS for: 801A Page 5 of 6 <<>> 9!1 77#=!%$% BBC9 A9 )*&,*A&B %,**A%B ,98 / @ &C%)#+ 5+ DE1,1) E @E%'%% / @ E5' "/ (E&!# /E' ' 1 798 5&# 2 797 C97 79C96 ""BG"D"B'57 4 8!;77# #827 7799 27267'B'47 797 827612 777 !7'B' 2 8 996""BG" D"B'777 7 7982 M827279 6 7 72 #!7#!7! 77298 8998 5 4#6,7 7 7!4 777 798 ;778798277! #; 77 #2 848 4 #!7#!77726 BRevisedA$A&( <<>> minus. of Transportation U.S.Department Washington, D.C. 20594 100 Seventh Street, S.V 1 Special Programs Research and APR 1 7 1998 Administration Mr. Gary P. Velikanje President Wood Kote Products, Inc 8000 N.E. 14t Place Portland, OR 97211 1 Dear Mr. Velikanje: This is in response to your letter of October 16, 1997, regarding the packaging of a two component wood bleach kit consisting of an aqueous solution of hydrogen peroxide (28%) and an aqueous solution of sodium hydroxide with a buffer of silicic acid. You request clarification under the provisions of the Hazardous Materials Regulations (HMR; 49 CPR Parts 171-180). Specifically, you asked if a two part kit consisting of one inner container of a material described as Hydrogen peroxide, aqueous solution, 5.1, UN 2014 with a Class 8 subsidiary hazard, and one inner container of a material describe as Sodium hydroxide solution, 8, UN 1824, PG II may be placed in the same outside packaging for transport by vessel. You expressed concern that ocean carriers will not accept these shipments although they have been prepared in accordance with the HMR and the International Maritime Dangerous Goods (IMGD) Code. Yes, these materials may be packaged together in the same outside package provided they are in accordance with 49 CFR 173.21 (e). As indicated in paragraph 3.6 in Annex I of the General Introduction to the IMDG Code, Amendment 28 (see IMDG Code page 0509), a corresponding provision specifies that materials may not be packaged together in the same outer packaging with other materiai if they react dangerously to each other and cause combustion and/or evolution of considerable heat, evolution of flammable, poisonous or asphyxiate gases, or the formation of corrosive or unstable substances. In addition, it is the shippers responsibility to ensure that your materials are properly packaged, marked and labeled. Each material within the package, must be described on the shipping paper and marked on the outside package. The package must be labeled with a Division 5.1 label and a Class 8 label for the primary hazard of the materials. • I hope that this information is helpful. If you need further assistance, please contact us. Sincerely, DelmerF. Billings Chief, Regulations Development Office of Hazardous Materials Standards <<>> OCT-16-97 04:40 PM WOOD. KOTE-PRODUCTS. INC 503 285 8374 P.02 File: 11321 WOOD-KOTE® MANUFACTURERS OF WOOD FINISHES 16 October, 1997 Office of Hazardous Materials Standards Edward T Mazzullo, Director Research and Special Programs Administration US DEPARTMENT OF TRANSPORTATION Washington DC 20590 400 7th st SW : • Via: Fax (202-366-8700] and USPS Priority Mail Re: Request for clarification Mr Mazzullo: 1am wilting to request the assistance of your office. We manufacture and market a two component wood Bleach Kit. The components are: Part A, an aqueous solution of Hydrogen Acid. Each component is packaged in heavy duty polyethylene bottles (16 oz, 32 oz or 1 gal). peroxide (28%) and Part Ban aqueous solution of Sodium Hydroxide with a buffer of Silicic: ::. the two bottles for the 16 oz and 32 oz kits are then enclosed in a plastic bag which is then laced into a light weight fiberboard box and then packed 8 kits in a UN specified heavy weigh • herboard carton with each Part "A" component enclosed in a plastic bag, iberboard carton. The gallon kits are packaged with 2 kits per UN specified heavy weight Should the two components leak and combine they will not react dangerously with each other, • • • or vapors, or the formation of corrosive or unstable substances, The two components combined cause combustion or evolution of considerable heat, evolution of flammable or poisonous gases are, in fact, less dangerous than cach individually. I have, for your reference, enclosed the following MSDS's: Part "A" Product Description Product Code Part "B" 800-WB-A Part "A" & "B" combined ratio 1:1 800-WB-B 800-WB-B 1 am also enclosing photocopies of letters you have provided to the WM Barr Co. Our wood labeling is reversed. Our concern is the same as WM Barr's addressed in your 08 November bleach is equivalent to the Klean-Strip Wood Bleach they produce except the "A" and "B" wood bleach and would like to have clarification addressed to Wood Kote to present to the 1995, lelter, We want to be able to make domestic and international marine shipments of our Shipping authorities. Would it be possible for you to provide a clarification letter addressed to Wood Kote which states segregation requirements chumerated in the IMDG Code page 0129 15.1.16 and 49CFR Sec that our wood Bleach components are compatible for shipment together and therefore the 176.83(b) & (c) (2) (iil) do not apply? 8000 N.E. 14th Place - Portfand, Oregon 97211 USA • P.O. Box 17192 - Portland, Oregon 97217 USA Tel: 503-285-8371 • 800-843-7666 (USA & Canada) • Fax: 503-285-8374 E-Mail: woodkole@teledort.com • Home nane: httn://www.wondkote.com <<>> OCT-16-97 04:41 PM WOOD. KOTE. PRODUCTS. INC 503 285 8374 P.03 he documentation we are seeking. If so, please do not hesitate to contact us by telephone, 800. assume you may have questions and may require additional Information before you can issue 843-7666 or fax 503-285-8374. I thank you, in advance, for your prompt attention to this matter. Yours truly, Gaty P Velikanje, President WOOD KOTE PRODUCTS, INC • enclosures cc: T Nash ... •• • т.. <<>> • SAFETY DATA SHEET WOOD KOTE PRODUCTS INC. www.woodkote.com Section 1: Product and Company Identification Product Name: Lite-N-Up Part "A" (Wood Bleach) Product Code: 801A 8000 NE 14th Place WOOD KOTE PRODUCTS INC. TEL: 503-285-8371 Portland, Oregon 97211 800-843-7666 (Toll Free USA & Canada) USA E-MAIL: info@woodkote.com FAX: 503-285-8374 EMERGENCY CONTACT INFOTRAC (Transportation): 800-535-5053 Product Use: Intended for professional use only. Wood Bleach component intended to be combined in equal proportions with Lite-N-Up Part "B" (Product Code 802B) Section 2: Hazards Identification GHS Ratings: Oral Toxicity Oxidizing liquid Acute Tox. 4 2 Oxidizing liquid class 2 Dermal Toxicity Acute Tox. 4 Dermal>1000+<=2000mg/kg Oral>300+<=2000mg/kg Skin corrosive 2 2.3 ‹ 4.0 or persistent inflammation. Reversible adverse effects in dermal tissue. Draize score: >= Eye corrosive 1 Serious eye damage: irreversible damage 21 days after Organ toxin single exposure Transie - **truncated:** true - **body characters:** 90918