{"operation":"document","citation":"99-0105","title":"Chem Lab Products, Inc. — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1999-06-23","effective_on":null,"summary":"99-0105 response to Chem Lab Products, Inc. concerning 172.101.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-99-0105.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-99-0105.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-99-0105","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/1999/990105.pdf","body":"<<<PAGE 1>>>\n\nOr resortions\nWashington, D.C.\n400 Seventh Street, S.W.\n20590\nJUN 2 3 1999\nMr. Dana Wm. Somesla\nRef. No. 99-0105\nChem Lab Products, Inc.\n5160 East Airport Drive\nOntario, CA 91761-7611\nDear Mr. Somesla:\nThis is in response to your letter dated April 15, 1999, requesting clarification on the proper\nclassification of your mixture containing 95% trichloroisoçyanuric acid and 5% boric acid, which is\nused as a flame retardant, under the Hazardous Materials Regulations (HMR; Parts 171-180).\nUnder § 173.22, it is the shipper's responsibility to properly classify and describe a hazardous\nmaterial. This Office generally does not perform this function. However, we provide assistance\nwhen we have the information available. Trichloroisocyanuric acid, dry is listed as a Division 5.1\noxidizing material in the Hazardous Materials Table (HMT) under the HMR. You state that your\nmixture is produced both in powdered and compressed (tableted) form. Your test data indicates\nthat the mixture does not meet the defining criteria for either a Division 5.1 oxidizing material or a\nDivision 4.1 flammable solid material. Therefore, if your mixture does not meet any other hazard\nclass defining criteria in Part 173, and is not a hazardous waste, hazardous substance, or marine\npollutant, it is not subject to the HMR.\nI hope this satisfies your inquiry.\nSincerely,\nSilm\nDelmer F. Billings\nChief, Standards Development\nOffice of Hazardous Materials Standards\n990105\n172.101(7)\n\n<<<PAGE 2>>>\n\nCHEM LAB PRODUCTS, INC.\nBoothe\nKem\n5160 East Airport Drive\nтек\nOntario, California 91761-7611\n§172.101 T\nTrichloroisocyanuric\nacic\n99-0105\nMr. Edward T. Mazzullo, Director\nU.S. Department of Transportation\nRoom 8102\nOffice of Hazardous Materials Standards\n407th Street, SW\nWashington, D.C 20590-0001\nApril 15, 1999\nI am seeking a determination as to the proper shipping classification for ground transportation of\na family of products we manufacture. These products are all packaged for and sold in retail\nestablishments. They range in size from 6 ounces to 37½ pounds per unit package. These products are\nall various size tablets of a blended mixture used for swimming pool chlorination.\nThe mixture consists of 95% trichloroisocyanuric acid; UN2468, PG II, oxidizer (5.1) and 5%\nboric acid; a flame retardant. Samples of the product in both its powdered and compressed (tableted)\nform were tested at a certified laboratory using UN procedures for 5.1 and 4.1 materials. Based on these\ntest results the products are not classified as either a 5.1 or 4.1 material for ground transportation. A\ncopy of the test results is enclosed for your review. It is my understanding that this is what the DOT\nrequires for classification or in this case de-classification of a material for shipping purposes.\nIn support of this I have found a similar product which has been acknowledged in 49 CFR.\nSodium dichloroisocyanurate salt (UN2465) is classified 5.1 in the anhydrous form and unclassified (49\nCFR, Chapter 1, 172.102 Special Provisions, Code/Special Provisions #28) in its dihydrate form.\nAccording to the manufacturer of these products UN 5.1 Classification testing was used to make this\ndetermination. Like our product one form is PG II, 5.1 meaning it increases the burn rate and in another\nform it no longer causes ignition per the 5.1 Standard\nAlthough this is not used by the DOT to make determinations, I am also including for reference\nNFPA data, which looks at the effect of tabletized trichloroisocyanuric acid in a fire situation. The test\nconcludes that tablets may be classified as a Class I Oxidizer (lower risk) from the original Class Il of\ntrichloroisocyanuric acid because they actually inhibit the burn rate compared to unfilled packaging\nmaterials consisting of plastic bottles and corrugated boxes. This would seem to support the relative\nsafety of these products. Similarly the Sodium dichloroisocyanurate drops from NFPA Class III\nOxidizer in its anhydrous form to a Class I it's reasonable to assume that the mixture we produce should\nbe rated like the Sodium dichloroisocyanurate dihydrate, which as previously stated, is shipped as a non-\nregulated material.\nFULL SPECTRUM OF QUALITY PRODUCTS AND SERVICES SINCE 1959\n\n<<<PAGE 3>>>\n\nBecause of my unfamiliarity with the consequences of this determination request I would appreciate\nsome indication in your response as to what to expect. My present understanding is that this might\nresult in a notice in the Federal Register followed by publication in the Special Provisions of 49 CFR\nwhen the next volume is published. This also may actually exceed what will occur. If the only response\nis a letter from your office then that will at least take care of our immediate needs.\nThank you for your time and consideration. If you have any questions or require additional\ninformation please contact me at (909) 390-9912 extension 253.\nYours truly,\nDana Wm. Somesla, Chemist","truncated":false,"body_characters":4928}