Wood Kote Products, Inc — Hazardous Materials Safety Interpretation

Page 1minus. U.S.Department of Transportation 400 Seventh Street, S.W t 1 Special Program: Research and APR 1 7 1998 Washington, D.C. 20590 Administration Mr. Gary P. Velikanje President Wood Kote Products, Inc 8000 N.E. 14th 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 CFR Parts 171-180). i 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 material it 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#

Page 2OCT-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: I am willing 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 Peroxide (28%) and Part "B", an aqueous solution of Sodium Hydroxide with a buffer of Stlicic : ::.. Acid. Each component is packaged in heavy duty polyethylene bottles (16 oz, 32 oz or 1 gal). ne two poles for the 16 oz and 32 oz kits are then enclosed in a plastic bag which is the laced into a light weight fiberboard box and then packed 6 kits in a UN specified heavy weigl "peroard carton with each Part "A" component enclosed in a plastic bag, fiberboard cartor. The gallon kits are packaged with 2 kits per UN specified heavy weight Should the two components leak and combine they will not react clangerously 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, leller. 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) (ill) 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: woadkote@teleport.com • Home name: htt://www.wnndkote.com#

Page 30CT-16-97 04:41 PM WOOD. KOTE. PRODUCTS. INC 503 285 8374 P.03 assume you may have questions and may require additional Information before you can issue 843-7666 or fax 503-285-8374. he documentation we are seeking. If so, please do not hesitate to contact us by telephone, 800. I thank you, in advance, for your prompt attention to this matter. Yours truly. Gaty P Velikanje, President WOOD KOTE PRODUCTS, INC • enclosures cG: T Nash ... •• •#