BOC Gases — Hazardous Materials Safety Interpretation

Page 1U.S.Department • of Transportation Washington, D.C. 400 Seventh Street, S.W. 20590 • OCT | 6 1998 Mr. John N. Thompson Hazardous Materials Specialist Ref. No. 98-0230 BOC Gases 600 Union Landing Road Riverton, NJ 08077 Dear Mr. Thompson: This is in response to your letter dated August 5, 1998, requesting clarification on the proper description of your gas mixtures under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you are requesting clarification on the proper shipping name and identification number for a mixture of any one or more of the following gases: argon, helium, krypton, neon or xenon in oxygen. You ask whether the proper shipping name for your mixtures should be "rare gases and oxygen mixtures, compressed, UN 1980" or "compressed gas, oxidizing, nos, UN 3156" when the oxygen concentration is greater than 23.5%. Section 172.101 requires that the closest name for the material compatible with the hazard class of the material be used. A mixture containing more than 23.5% oxygen is considered to be an oxidizing gas. Therefore, the proper shipping name, "compressed gas, oxidizing, nos, UN 3156" is more appropriate. I hope this satisfies your inquiry. Sincerely, Jah elmer F. Billings Chief, Standards Development Office of Hazardous Materials Standards#

Page 2300t€ TIL BOC GASES BOC Gases 172.101 (K) Kare Gase P.O. Drawer No. 272 Union Landing & River Road: Riverton NJ 08077 Telephones: 609 829 7878 August 5, 1998 Delmer Billings U.S Department of Transportation Research & Special Programs Administration Office of Hazardous Materials Safety 400 Seventh Street, SW Washington, D.C. 20590 - Dear: Mr. Billings Could you please clarify for BOC Gases the following questions? What would be the Proper shipping name and Identification number for a mixture of any one or more of the following gases; argon, helium, krypton, neon or xenon in oxygen? Would it not be Rare gases and oxygen mixtures, compressed, UN 1980? What if the oxygen concentration was greater then 23.5%, would it then be described as Compressed gas, oxidizing, N.O.S., UN 3256? In the Hazardous Materials Table you have Carbon dioxide and oxygen mixtures, compressed listed with Special Provision 77, which requires you to add a subsidiary oxidizer hazard label when the oxygen concentration is greater then 23.5% would not or could the same be applied to the Rare gases and oxygen mixtures, compressed entry? We want to insure that we are properly labeling these cylinders in compliance with the regulations. Clarification of this matter would do this. Thank you for any information you could provide on this matter. Please respond to me at BOC Gases, 600 Union Landing Road, Riverton, New Jersey, 08077, phone: ( 609) 786-2906. A Delaware Corporation A division of The BOC Group, Inc.#

Page 3Sincerely, BOC Gases pim X. Thompson ohn N. Thompson Hazardous Materials Specialist#

Page 4of Transportation U.S.Department Washington, DC 400 Seventh Streel Sw 20590 Research and Special Programs Administration JUL 213= Project Supervisor Mr. Jeff R. Bowman Environmental Dynamics 1916 Grandstand Dr. san Antonio, TX Dear Mr. Bowman: This is in response to your letter of April 14, 1993, regarding transportation of oil soaked rags. material referred to does not meet the definitions of a flammable solid or a As discussed with you by MI. John Gale of our staff, the debris-soaked spontaneously combustible material in S 173.124. For example, oil soaked rags are not characterized as readily combustible materials which may cause a fire through friction, nor are oil soaked rags likely to meet the definition of self heating materials exhibiting spontaneous ignition at temperatures exceeding 200°F during a 24 hour test period. S 173.120 (C), is one criterion used to determine whether a liquid ia Flash point, defined in classified as combustible or flammable material. Protection Agency (EPA) requirements, they would be subject to the appropriate However, if the oil soaked rags are a hazardous waste under Environmental requirements under the Hazardous Materials Regulations. Ior more information, call the EPA RCRA Botline at 1-800-424-9346. If we can be of further assistance, please feel free to contact us. sincerely, Delmer I. Billings Acting Deputy Director, office of Hazardous Materials standards 181/173.124 172.10/ 93-0124#