Tamaya Chemical Corporation — Hazardous Materials Safety Interpretation

Page 1of Transportation US. Department 400 Sigion, SC 20590 Research and Washinglon, D.C Special Programs FEB - 3 1998 Administration Ms. Sarah Hall. President, Tamaya Chemical Corporation 500 North Birdneck Road, Suite 100 Virginia Beach, Virginia 23451 Dear Ms. Hall: This responds to your letter requesting information concerning the applicability of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) to iodine (99.5% purity). Specifically, you ask that this office update the information contained in a letter to you dated August 11, 1994. The information that we provided in our earlier letter is accurate. Under the HMR, a shipper must properly classify, package, mark, and label a hazardous material for transportation in commerce. The criteria for making determinations as to the hazard class of a material can be found in Part 173 of the HMR. It is not necessary for a shipper to confirm its classification of a hazardous material with the Department of Transportation. Based on the information available to this office, iodine (solid, 99.5% pure) does not meet the pure) are not subject to the requirements of the HMR. definition of any hazard class as set forth in Part 173. Thus, shipments of iodine (solid, 99.5% If you require additional information, you may wish to contact the Hazardous Materials Information Center at 1-800-467-4922. A hazardous materials transportation safety specialist is available to answer questions on the requirements of the HMR between the hours of 9:00 am and 5:00 pm Monday through Friday (except federal holidays). I hope this information is helpful. If you need anything further, please do not hesitate to contact me. Sincerely, Alan I. Roberts Associate Administrator for Hazardous Materials Safety#

Page 2TAMAYA CHEMICAL CORPORATION 1 January 13, 1998 • • Patricia Klinger Administrator's Office U.S. Department of Transportation Research and Special Programs Administration Dear Patricia: DOT Classification and shipping regulations for Iodine 99.5% purity. A copy of Tamaya Chemical needs an updated statement, in writing, as to the status of the U.S. your previous response to this request is enclosed for your reference. In the past, it has taken as long as nine months and the intervention of a congressman to obtain an answer to this request. Please verify as to whether there has been any change to at (757) 422-9685. the status for shipping Iodine. I can be reached by phone at (757) 422-1884 or by FAX Thank you for your prompt attention. Sincerely, Darah Hall Sarah Hall President cc: Owen Pickett • : : 500 N. BIRDNECK RD., SUITE 100 • VIRGINIA BEACH, VA 23451 • TELEPHONE: (757) 422-1884 • FAX: (757) 422-6856#

Page 3RESEARCH AND SPECIAL PROGRAMS ADMINISTRATION CORRESPONDENCE CONTROL FORM DUE IN S-10/1-10: DUE IN DPP-10:-2/5/98~ DOCUMENT SUMMARY: Requestior S DAM iodine status of shipping regulations for z CONTROL NUMBER: DEL 11:43 981954-CLISERM CORRESPONDENCE FROM: SIGNATURE LEVEL: Sarah Hall ¡ Kolley 8. Goynor → AL Roberts ACTION TO BE TAKEN: Prepare Response COMMENTS: CONCURRENCES CURRENT ROUTE DRP/DPP CONCURRENCE ROUTE DATE APPROVED DRP-1 DRP-2 DPP-1 DPP-2 [DPP-3#

Page 4.... • U.S. Department of Transportation 400 Seventh Street, S.W. Research and Washingion, D.C. 20590 Special Programs Administration August 11, 1994 • Ms. Sarah Hall President 1062 Laskin Road, Suite 11A Tamaya Chemical Corporation Virginia Beach, VA 23451 Dear Ms. Hall: Pursuant to our telephone conversation and in response to your recent letter dated July 20, 1994, regarding the DOT classification of iodine. Under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171- marking, and labeling a hazardous materials for transportation in 180), a shipper 1s responsible for properly classifying, packaging, material commerce is based on the The shipper's determination of the hazard class of a material when compared to the defining criteria for hazardous chemical and physical hazards of a materials (see section 173.22). Except for explosives which are classed by the Department, it is not necessary for a shipper to Department. confirm its classification of a hazardous material with the Materials Safety, Based on the information available to the Office of Hazardous definition of a poison (see section 173.132) OF other hazard class . iodine, solid (99.5% does not meet criteria and is not subject to the HMR. of the sections mentioned. "Enclosed you will' copies I hope this information is helpful. Sincerely, Patricia klug Patricia Klinger Enclosures :#