Interpretation Response #00-0256 ([Air Products and Chemicals, Inc.] [Mr. Donald R. Silfies])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Air Products and Chemicals, Inc.
Individual Name: Mr. Donald R. Silfies
Location State: PA Country: US
View the Interpretation Document
Response text:
October 27, 2000
Mr. Donald R. Silfies Ref. No. 00-0256
Senior Safety Specialist
Air Products and Chemicals, Inc.
7201 Hamilton Boulevard
Allentown, Pennsylvania 18195
Dear Mr. Silfies:
This responds to your letter, dated September 8, 2000, concerning regulatory requirements for transporting hydrogen fluoride, anhydrous. Specifically, you ask about labeling and placarding requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).
Your understanding of the HMR requirements for hydrogen fluoride, anhydrous, is correct. Because it meets the definition of a material poisonous by inhalation (PIH) in § 171.8, shipments of hydrogen fluoride, anhydrous, must conform to specific shipping paper, package marking, and placarding regulations applicable to PIH materials. Thus, the shipping paper must include the words “Poison - Inhalation Hazard, Zone C” immediately following the shipping description (§ 172.203(m)(3)). Further, the package must be marked “Inhalation Hazard” (§ 172.313(a)). In addition, the transport vehicle or freight container must be placarded with a POISON INHALATION HAZARD placard in addition to any other required placards (§ 172.505(a)).
You are also correct that the labels required under the HMR for packages containing hydrogen fluoride, anhydrous, do not communicate that it is a PIH material. As you note, the regulations require a CORROSIVE label to indicate the material's primary hazard and a POISON label to indicate the material's subsidiary hazard. These requirements are consistent with international regulations in the UN Recommendations on the Transport of Dangerous Goods.
The HMR permit you to apply labels in addition to those listed in the Hazardous Materials Table (HMT) for a given hazardous material provided the label accurately represents a hazard of the hazardous material in the package. For hydrogen fluoride, anhydrous, you may use a POISON INHALATION HAZARD label in addition to the CORROSIVE and POISON labels listed in Column (6) of the HMT.
We agree with you that the current HMR requirements for labeling packages of hydrogen fluoride, anhydrous, are confusing and do not accurately convey the hazard presented by the material. We plan to address this confusion in an upcoming rulemaking.
I hope this information is helpful. If you have further questions, please do not hesitate to contact this office.
Sincerely,
Senior Transportation Regulations Specialist
Office of Hazardous Materials Standards
172.313
Regulation Sections
| Section | Subject |
|---|---|
| 172.313 | Poisonous hazardous materials |