# Elkem Metals Company — Hazardous Materials Safety Interpretation

- **operation:** document
- **citation:** 98-0525
- **title:** Elkem Metals Company — Hazardous Materials Safety Interpretation
- **source type:** guidance
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** guidance
- **official:** true
- **published on:** 1998-03-02
- **effective on:** Not available
- **summary:** 98-0525 response to Elkem Metals Company concerning 173.124.
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-interpretation-98-0525.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-interpretation-98-0525.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-interpretation-98-0525
- **source url:** https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/1998/980525.pdf
**body:**

<<<PAGE 1>>>

-
of Transportation
U.S. Department
400 Seventh Street, S.W.
Washington, D.C.
Special Programs
Research and
20590
Administration
MAR - 2 1998
Ms. Sharon L. Thompson
Manager-Traffic and Distribution
Elkem Metals Company
Post Office Box 72
Marietta, Ohio 45750-0072
Dear Ms. Thompson:
This is in response to your letter dated October 30, 1997, requesting confirmation that your
company's ferrosilicon is not subject to the Hazardous Materials Regulations (HMR; 49 CFR
Parts 171-180). You state that your product was tested in accordance with the test method
described in Appendix E to Part 173, and found it does not meet the definition of a Division
4.3 (Dangerous When Wet) material.
As provided in § 173.22, it is the shipper's responsibility to properly classify a hazardous
material. However, based on the test data you provided, we concur that your company's
ferrosilicon with 50% ferrosilicon does not meet the definition of a Division 4.3 material.
Therefore, if your company's material does not meet any other hazard class definition of Part
173 it is not subject to the HMR.
I hope this satisfies your request.
Sincerely,
Delon Hilling
Delmer F. Billings
Chief, Standards Development
Office of Hazardous Materials Standards

<<<PAGE 2>>>

•
& Elkem
Dale
PAi!
700. 173,124
1322
October 30, 1997
Ms. J. Suzanne Hedgepeth
Director
Office of Hazardous Materials
U.S. Department of Transportation
+00 Seventh Street. S.W.
Research & Special Programs Administration
Washington. D.C. 20590
Dear Ms. Hedgepath:
In accordance with the rules set forth in U.S. DOT 49 CFR 173, Appendix E, Elkem performed
in Division 4.3. Based on the attached findings. we do not believe our product meets the criteria as it did
the test as described on our 50% Ferrosilicon to determine if our product met the criteria for classification
not spontaneously ignite nor was there any gas evolution observed.
not meet the 4.3 definition.
We would appreciate your review of the attached report and confirmation that our product does
Sincerely,
Star 1. Thompan
Manager - Traffic and Distribution
Sharon L. Thompson
Enclosures
ELKEM METALS COMPANY MARKETING SERVICES; P.O. BOX 72; MARIETTA, OHIO 45750-0072
Quality i
Ош
Telephone: (800) 848-9795
Fax: (614) 374-1043
PRIORITY

<<<PAGE 3>>>

i x
Results of the tests performed on Elkem's regular 50 % FeSi (50 wt. %
Si) using DOT procedures.
(09/29/97)
E. G. Allain, F. X. He, D. G. C. Robertson
Center for Pyrometallurgy
Department of Metallurgical Engineering
University of Missouri-Rolla
Summary
was used to test Elkem's 50 % ferrosilicon material. The sample was sieved to determine
the particle size distribution after handling and transportation. The percentage of particles
of less than 500 micrometers was 0.23%. Therefore, according to the DOT instructions,
the material did not need to be ground for testing. Results of the three tests recommended
by the U.S. DOT show that no gas evolution or spontaneous ignition was observed when
Elkem's 50 % ferrosilicon was put in contact with distilled water.
Aims
The aim of this report is to provide to Elkem the results obtained during the tests
of Elkem's 50 % FeSi (50 wt. % Si) in applying rigorously the instructions indicated in
the U.S. DOT 49 CFR 173, appendix E, entitled "Guidelines for the Classification and
Packing Group Assignment of Class 4 Materials", division 4.3. This division gives the
test conditions for the classification of "dangerous when wet" materials.
1. Material
The Elkem's 50% Fesi material was sent to UMR in a drum. As received, it
mainly contained pieces measuring from about one to ten centimeters. However, it also
included a relatively low amount of powder. The total weight of this material was 11,362
grams.

<<<PAGE 4>>>

2. Tests procedure and results
2. 1. Preliminary sieving test
The U.S. DOT 49 CFR 173, appendix E, division 4.3 gives in section "a). Test
method" the following specifications:
"For a solid material, the package should be inspected for any particles < 500 um
diameter. If that powder constitutes more than 1 percent (mass) of the total or if the
material is friable, then the whole of the sample should be ground to a powder before
testing to allow for a reduction in particle size during handling and transport,
otherwise the material should be tested in its commercial state"
Therefore, the totality of the as-received Elkem's 50 % FeSi material was sieved three
times, during 10 minutes, using the following equipment:
- A series of 8 sieves of the Tyler Standard Screen Scale (From 3 Mesh to 28 Mesh).
The 500 um opening (32 Mesh Tyler equivalent) sieve was taken from a U S
standard sieving series. Openings of these sieves are given in Table I.
- A shaking apparatus model "COMBS gyratory sifting machine", manufactured by
Greet Western Mfg. Co., Kansas.
As indicated in Table II, the amount of particles ‹ 500 um constituted less than 0.23
% of the weight of the as received 50% FeSi material. It was also found that this material
was not friable (at least to handling in the laboratory). Therefore, the further tests
recommended by the DOT should be performed in its commercial state.
Table I: Characteristics of sieves used to sift the Elkem's 50 % FeSi
Meshes to the inch
Opening (in)
Opening (mm)
3
0.263
6.680
4
0.185
4.699
6
0.131
3.327
8
0.093
2.362
10
0.065
1.651
14
0.046
1.168
20
0.0328
0.083
28
0.0232
0.589
Tyler equivalent 32*
0.0197
0.500*
Sieve taken from a US standard sieving series.
:

<<<PAGE 5>>>

in it
•
•
:
Table II: Size distribution of the as received Elkem's 50 % FeSi
# Test 1
# Test 2
#Test 3
Average
Screen
Size
Weight
(g)
retained
Wt %,
Weight
Wt%,
Weight
Wt%,
Weight
Wt %,
(g)
retained
(g)
retained
(g)
retained
+3M
11318.60
99.634 11319.38
99.642 11319.39
99.644 11319.12
99.640
-3M+4M
6.25
0.055
4.90
0.043
5.470
0.048
5.540
0.049
4M+6M
0.67
0.006
1.25
0.011
0.660
0.860
0.008
SM+8M
1.400
0.012
1.08
0.010
1.010
0.010
-8M+10 M
1.19
0.010
1.38
0.012
1.470
0.012
-10M+ 14 M
1.33
0.012
1.28
0.011
1.230
0.011
-14M+ 20 M
1.53
0.013
1.45
0.013
1.470
0.013
-20M+ 28 M
1.85
0.016
1.92
0.017
1.840
0.016
0.016
-28M+ 32 M
1.25
0.011
1.24
0.011
1.290
0.011
1.260
0.011
-32 M*
26.12
0.230
26.13
0.230
25.990
0.229
26.080
0.230
Total
11360.19
100
11360.01
100
11359.82
100
11360.00
100
* <500 um

<<<PAGE 6>>>

?.
3. Tests to detect spontaneous ignition or gas evolution.
3. 1. Tests Procedure
The U.S. DOT 49 CFR 173, appendix E, division 4.3 specifies four different tests
to determine whether the reaction of a material with water leads to the development of a
dangerous amount of gases which may be flammable or toxic. The first three tests are
described in terms indicated below:
Test (1): "A small quantity (approximately 2mm diameter) of the test material is placed
in a trough of distilled water at 20 °C. It is noted whether any gas is evolved and
if it spontaneously ignites."
Test (2): "A small quantity of the test material (approximately 2mm diameter) is placed
in the center of a filter paper which is floated flat on the surface of distilled
water at 20 °C in a 100 mm diameter evaporating dish. The filter paper is to
keep the material in one place, under which condition the likelihood of
spontaneous ignition of any gas is greatest. It is noted whether any gas is
evolved and if it spontaneously ignites."
Test (3): "The test material is made into a pile approximately 2 cm high and 3 cm in
diameter with an indentation in the top. A few drops of water are added to the
hollow. It is noted whether any gas is evolved and if it spontaneously ignites."
3. 2. Results
3. 2. 1. Test (1)
Three samples of the as-received Elkem's 50% FeSi material were submitted in
triplicate to this test. They were put in a trough containing about 80 cm of distilled water,
during 20 minutes. The sample characteristics are the following:
Sample 1: A piece of about 2mm diameter taken from the + 3 Mesh fraction size.
Sample 2: A piece of about 2mm diameter taken from the - 3 Mesh to + 32 Mesh
fraction size.
Sample 3: 0.5 gram of the powder from the - 32 Mesh fraction size.
Table III summarizes the results obtained during test (1). It shows that no
spontaneous ignition or gas evolution occurred in this test condition.
Table III: Results of test (1)
Sample/Test
N° 1
N° 2
N° 3
Sample 1
N. S. I.*, N.G. E.**
N. S. I., N.G. E.
N. S. I., N.G. E.
Sample 2
N. S. I., N.G. E.
N. S. I., N.G. E.
N. S. I., N.G. E.
Sample 3
N. S. I., N.G. E.
N. S. I., N.G. E.
N. S. I., N.G. E.
* N. S. I.: No Spontaneous Ignition, ** N.G. E.: No Gas Evolution

<<<PAGE 7>>>

...
•
•
3. 2. 2. Test (2)
Three samples of the as-received Elkem's 50 % FeSi material were submitted in
triplicate to this test. These samples have the same characteristics as those described
above for test (1). They were put on a filter paper floating on distilled water contained in
a 10-cm diameter evaporating dish, during 20 minutes.
Table IV shows the results obtained during this test. It indicates that no
spontaneous ignition or gas evolution occurred during the three tests.
Table IV: Results of test (2)
Sample/Test
N° 1
N° 2
N° 3
Sample 1
N. S. I.*, N.G. E.**
N. S. I., N.G. E.
N. S. I., N.G. E.
Sample 2
N. S. I., N.G. E.
N. S. I., N.G. E.
N. S. I., N.G. E.
Sample 3
N. S. I., N.G. E.
N. S. I., N.G. E.
N. S. I., N.G. E.
* N. S. I.: No Spontaneous Ignition, ** N.G. E.: No Gas Evolution
3. 2. 3. Test (3)
Two samples of the as-received Elkem's 50 % FeSi material were submitted in
triplicate to this test. The sample characteristics were the following:
Sample 1: A piece of about 2 om high and 3 cm large taken from the + 3 Mesh
fraction size of the Elkem's 50 % FeSi material. A hollow of about 3-
mm depth was drilled at the top of this piece. Then, some drops of
water were added.
Sample 2: Some pieces of the Elkem's 50 % FeSi material were ground.to <80
um The resulting powder was packed into a small refractory crucible
of 2 cm high and 2 cm. A hollow of about 3-mm depth was made at
the top of this pile. Then, some drops of water were added.
Table V groups the results obtained during Test (3). It shows that no spontaneous
ignition or gas evolution occurred during the three tests.
Table V: Results of Test (3)
Sample/Test
N° 1
N° 2
N° 3
Sample 1
N. S. I.*
, N.G. E.**
N. S. I., N.G. E.
N. S. I., N.G. E.
Sample 2
N. S. I., N.G. E.
N. S. I., N.G. E.
N. S. I., N.G. E.
* N. S. I.: No Spontaneous Ignition, ** N.G. E.: No Gas Evolution

<<<PAGE 8>>>

3. 2. 4. Test (4)
Test (4): "Water is put into the dropping funnel and enough of the material up to a
maximum weight of 25 g) to produce between 100 cm' and 250 cm' of gas is
weighed and placed in a conical flask. The tap of the dropping funnel is opened
to let the water into the conical flask and a stop - watch is started. The volume
of gas evolved is measured by any suitable means. The time taken for all the
gas to be evolved is noted and, where possible, intermediate readings are taken.
The rate of evolution of gas is calculated over seven hours at 1-hour intervals.
If the rate of evolution is erratic or is increasing after 7 hours, the measuring
time should be extended to a maximum time of 5 days. The 5 day test may be
stopped if the rate of evolution becomes steady or continually decreases and
sufficient data has been established to assign a packing group to the material or
to determine that the material should not be classified in Division 4.3. If the
chemical identity of the gas is unknown, the gas should be tested for
flammability and toxicity."
The samples taken for this test weighed 25g of ground material. The experimental
apparatus used to measure the volume of gas that could evolve from the 50 % FeSi
consisted in a flask of 500 cm' connected to a U-tube having a 1/16-inch ID. This U-tube
was filled with water colored by the addition of a small amount of red ink. From the
results of previous tests the gas volume was expected to be very low or even equal to
zero. So, the change of the liquid position in the U-tube, due to the variation of the
pressure in the flask was expected to indicate us the gas volume evolved as function of
the time.
As specified by the DOT 49 CFR 173, the 25 grams 50 % FeSi Material were put
into contact with water in the flask. No ignition or gas evolution were observed. As
reported in table VI no variation of the water height was noticed in the U-tube, from the
beginning of the experiment through 7 hours. Hence, as recommended by DOT
specifications, the measurements were stopped.
Table VI: Results of Test (4)
Time (hours)
1
2
3
4
5
6
7
Ah* (mm)
0
0
0
Gas volume (mm?)
0
0
0
0
0
* Variation of the colored water height in the U-tube.

<<<PAGE 9>>>

3.2.5. Chemical analysis
A sample weighing about 200 grams was taken from the as received 11.4 kg
Elkem's 50% FeSi. This sample was ground and sieved to a powder of less than 80
micrometers. Then, four samples of five grams each were taken and sent to the MINTEK
Laboratories, Randburg, South Africa (See Appendix I). The four samples were analyzed
by emission spectroscopy to measure their Fe, Si, Al, Ca and Mg contents. Results are
given below in Table VII and in Appendix I.
Table VII: Results of chemical analysis of Elkem's 50 % FeSi.
Sample
Si %
Fe %
A1 %
Ca %
Mg %
2% *
1
50.5
47.9
0.65
< 0.2
< 0.1
99.35
2
50.2
47.7
0.62
< 0.2
< 0.1
98.82
3
50.7
47.6
0.61
< 0.2
< 0.1
99.21
4
50.1
47.6
0.62
< 0.2
< 0.1
98.62
Average.
50.4
47.7
0.63
< 0.2
< 0.1
99.03
* Total assuming that Ca = 0.2% and Mg = 0.1%
4. Conclusion
Elkem's 50% FeSi material was tested following the U.S. DOT method
procedure, specified in the U.S. DOT 49 CFR 173, appendix E. Test results lead to the
following conclusions:
The percentage of particles of less than 500 micrometers in the as-received
material was 0.23%,
No gas evolution or spontaneous ignition were observed when small quantity of
Elkem 50% FeSi is placed in a trough of distilled water at 20 °C,
No gas evolution or spontaneous ignition were observed when a small quantity of
Elkem 50% Fesi is placed in the center of a filter paper which is floated flat on
the surface of distilled water at 20 °C,
No gas evolution or spontaneous ignition were observed when few drops of water
were added at 20 °C into a hollow made in the top of a piece of Elkem 50% FeSi,
No gas evolution could be measured or even detected when water was put in
contact with a weight of 25 g of Elkem 50 % FeSi in a conical flask at 20 °C.
The chemical analysis of the Elkem 50% FeSi give an average content of 50.4%
Si, 47.7% Fe, 0.63 %Al, less than 0.2% Ca and less than 0.1% of Mg.

<<<PAGE 10>>>

APPENDIX I

<<<PAGE 11>>>

2509-94-
08:20 792 6650
MINTEK ASD
->0915733416934
Page 1 of →
Page 01
TELEFAX MESSAGE
Analytical Science Division
MINTEK
Facsimila
(011)-792-6650 (Local)
Tolophone (011)-709-4111
(2711)-782-6650 (Int')
Faksimileo (011)-723-2413 (Plans)
(2711)-792-6650 (Int')
Private Bag X3015, Randburg,
Telefaon (011)-709-4111
2125 South Africa
Privatsak X3015, Randburg,
2125 Suid-Afrike
CONFIDENTIALITY WARNING
The information in this facsimile message is privileged and confidential information intended solely for the use
of the addressed person or entities. If you are not such persons or antitles, you are hereby notified that any
distribution, dissemination or reproduction of this facsimile message, including the taking of any action in
response to the contents thereof, is strictly prohibited. If you have received this message in error, please call
us Immediately at the above number to arrange for the documents) to be returned at our cost.
Dnte: 97/09/25
09l
....
To: UNIVERSiTY OF MISSORI- ROLLA
Fax No:
(573)
34)
6934
::
For attention: DAVID ROBERTSON
Please
find
attached
results
for
the ferrosilicon
sambles submitted or
analysis.
Plase acknowledge receift of this
fax.
•
....
Kind regards:
•....
Sheena Maharaj

<<<PAGE 12>>>

i:rii...
.-..::.
...
----
...
"ri::.
.......
. ••
tintiniv
Sistaal Nr.
ictl No.
Project No.
Projek Nr.
Soction
EMISSION
SPECTROSOOPY
2K 739
[13189701
Seksic
EMISSIE-
SPEKTROSKOPIE
Rep
MINTEK
Ver
ATTI DAVID ROBERTSON
Spocialists in mineral and
metallurgicad tocanology
Tochnique/Plate No. SE002
Tegniek/Plaat Nr.
Results reported in
Resultate gerapporicer in
%
Date starled
Datum begin
97/09/01
Date reported
Datum gerapporteer
97/09/22
11g
Ae
Ca
Te
1
<0.1
0.65
1 D. 2
47.9
2
->0915733416934
0,62
3
0.62
47.7
0.59
47.6
4
V
0.62
V
47.6
5
6
MINTEK ASD
7
8
9
10
sample/Verw. monster
A167
50.1
value/Aanv. waarde
50.05
B ample/Verw. monster
wAany. waarde
Analyst
08:21
Analis
Time
No of determinations
1.
s, tu arsland.
Tyd
Getal bepalings
20
Checked by
Nagesien deur ..
1.
.....Hrs/uur Total time: Hrs
Approved by
25-09-97
2
Pobuhozr z
....Hrs/uur Totale Tyd: uur
Goedgekeur deu

<<<PAGE 13>>>

....
* Workshet no.
Werkstaat nr.
LAK 739
AITI DAVID ROBERTSON
MINTEK
Group- CHEMISTRY
Results reported in
Resultate gerapporteer in
%½
Project
Projok
1131897011
Datur begin 97/9/23
Date received
Date reported
Datur gerapporteer 97/9/2
Monster
Sample
Si
1
49,8
150,3
2
50,2
50,7
4
50,1
5
7
8
MINTEK ASD
10
Technique
Tegniek
Lab metode L 64
Lab, method.
Analyst
Analis
Tyd h
Time
Verwysingsmonster
Ref. sample
Bestanddeel
Constituent
Resultate
Results
1..A.
I VAN LENDER..
1
....
A167
S:
48,07
792 6650
2
• ...
3....
3...
4....
4...
Total time
Totale tyd
No. of determinations
25-09-97
Aantal bepalngs
Goedgekeur
Approved
- **truncated:** false
- **body characters:** 17303