ALM Safety Associates — Hazardous Materials Safety Interpretation

Page 1• of Transportation U.S. Department 400 Seventh Street, S.W. Special Programs Research and Washington, D.C. 20590 Administration MAY 15 1998 Mr. Allen L. Mossman ALM Safety Associates 65 Sarazen Street Saratoga Springs, NY 12866-8719 Dear Mr. Mossman: This is in response to your letter regarding the proper shipping name for mixtures containing oxygen under the Hazardous Materials Regulations (HMR; 49 Parts 171-180). You requested information explaining what concentration of oxygen in a gas mixture meets the oxidizing gas definition. RSPA has determined that concentrations of oxygen greater than 23.5% cause or contribute to the combustion of other material more than air does, and therefore meet the definition of oxidizing gas in § 171.8. RSPA will consider referencing Special Provision 77 for rare gases and oxygen mixtures containing more than 23.5% oxygen in a future rulemaking. This issue will be addressed at the next meeting of the United Nations Committee of Experts on the Transport of Dangerous Goods. I hope this answers your inquiry. If we can be of further assistance, please do not hesitate to contact us.#

Page 21:172.102 110 AIM Safety Associates 178 65 Sarazen Street • Saratoga Springs, NY 12866-8719 Phone 518-583-2528 Fax 518-583-2539 sui June : 25, 1997 office of Hazardous Materials Standards Delmer F. Billings, Chief • Regs. Dev. RSPA - US Dept. of Transportation Washington, DC 20590 400 Seventh Street, s.w. Dear Mr. Billings: I am in receipt of a copy of your letter of interpretation of June 19, 1997, to Richard P. Schweitzer, Esq. Last autumn I proposed questions to RSPA similar to those of Mr. Schweitzer's, mainly those relating to proper shipping descriptions for mixtures containing oxygen in concentrations high enough to be defined oxidizing, and the concentration above which the reply I received oxidizing classification should be used. Enclosed is a copy of the from RSPA. Can I assume, that with the publication of final HM215-B, that the supercedes the interpretation as expressed in your letter of June one I received in November? 18th now special provision If so, shouldn't mixtures? Also, since special provision 77 indicates that the Div. is no required to the ago so not above 23.5% for domestic transportation, should I assume that concentrations of oxygen? for international shipments the Div. 5.1 label is required for all I am currently doing consultation for a label printing company, and he answers to the above questions would help resolve a number oi utstanding problems related to the production of oxygen mixture We have been operating under the interpretations provided 1 or 0 90 10 7955 position regarding any revised rulingen best regards. want to be sure of our Sincerely, Allend Moreman Allen L. Mossman CC: R. Schweitzer R. M. Ackerman Lopez#