{"operation":"document","citation":"99-0078","title":"Willett Labeling Company — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1999-06-07","effective_on":null,"summary":"99-0078 response to Willett Labeling Company concerning 173.22.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-99-0078.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-99-0078.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-99-0078","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/1999/990078.pdf","body":"<<<PAGE 1>>>\n\n~\nof Transportation\nUS.Department\nWashington, D.C.\n400 Seventh Street, S.W.\n20590\nSpecial Programs\nResearch and\nAdministration\nJUN - 7 1999\nWillett Labeling Company\nMs. Alberta Millar\nRef. No.\n99-0078\n6314-A Airport Freeway\nFort Worth, TX\n76117-5332\n•\"::\nDear Ms. Millar:\nThis is in response to your fax dated March 25, 1999, and\nsubsequent telephone conversation with Eric Nelson of our\nstaff regarding the classification of pressurized canisters of\nMEK based ink under the Hazardous Materials Regulations (HMR;\n49 CFR Parts 171-180). Specifically, you ask for advice in\nclassifying these canisters.\nUnder § 173.22 of the HMR, it is the shipper's responsibility\nto properly classify a hazardous material.\nWe are sorry that\nwe can not further assist you in the classification of your\nproduct as the information provided to\nus in your fax and\nsubsequent telephone conversation is inadequate.\nGenerally,\nmanufacturers have the knowledge to properly classify the\nmaterials and products they produce, although it may be\nnecessary to enlist an outside laboratory to assist in the\nclassification process, as testing may have to be conducted to\nsee how a product compares to the criteria for various hazard\nclasses.\nI hope this satisfies your request.\nSincerely,\norma\nI. All\nThomas G. Allan\nActing Director, Office of Hazardous\nMaterials Standards\n173.22\n990078\n\n<<<PAGE 2>>>\n\n03/25/1999\n13:38\n81(LLL205.\n6314-A Airport Frwy.\nWillelt\nFort Worth, TX 76117-5322\ntel: (817) 222-2233\nfax: (817) 222-0466\nTHE WORLD'S CODING\nAND LABELING COMPANY\nFACSIMILE MESSAGE\nNo. Pages\n1\nDate:\nMarch 25, 1999\nTo:\nHazardous Materials Regulations Information\nFrom:\nAlberta Millar - Consumables Product Manager\nSubject:\nClassification enquiry\nPlease find to follow my question.\nI look forward to hearing from you soon.\nKind regards\nAllillar.\nAlberta Millar\n\n<<<PAGE 3>>>\n\nFor our new Willett printer we supply pressurised canisters that contain a small bag of\nMEK based ink. We are having problems with the classification of this product for\ntransport by air. At the moment on the canisters we have the UN number for a flammable\nliquid and on the box carrying the canisters the UN number is for a flammable gas.\nThe canisters are not aerosols as there is no nozzle on the top of the canister to atomize\nthe ink and the pressurised air (Propellant) is not expelled with the product. The canister\nfits into a printer and the ink is not released into the atmosphere until the bag is collapsed\nby the compressed media around it, in turn feeding the ink to a system where it is printed\nvia separate means. (in the form of large droplets which are formed by solenoid valves\ninside the printhead.)\nDuring can assembly, the bag inside the can is empty and the can itself is pressurised\nwith air. During the filling, 297ml of MEK based ink is put into the bag, at this time the\nincrease in the internal volume inside the can pressurises further the air inside the can.\nThe initial pressure of the air is 54psi and the final pressure is 140psi.) Therefore, at this\nstage the canister cannot be classed as containing a flammable gas.\nThe bag the ink is in is generally impermeable, however, we suspect that MEK vapours\ncan actually diffuse through the bag, potentially allowing a mixture of MEK and air\nmaking a flammable mixture of gases. However, at some point, the level of MEK\nvapours inside the can will reach saturation point and will theréfore become non-\nflammable withour the addition of air. If the can is punctured, the MEK vapours would\nbe released into the atmosphere, again at some point reaching the LEL associated with\nMEK, creating a flammable mixture of gases.\nPlease could advise us on the correct classification for these canisters.\n\"It can be noted that similar types of product are in\nthe domestic market, such as shaving\nfoams marketed by Gillette as\nshaving gel these products however use a flammable\ncompressed charge to collapse the internal bag such as a Butane derivative.\n173.308\nwhat tup is 10 psi indicated? (130°8) Botze\nhot waiter berth test\nASTM E Gil -85\n167, 10s","truncated":false,"body_characters":4073}