Interpretation Response #04-0285 ([The Field Museum] [Ms. Jolynn Parchen])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: The Field Museum
Individual Name: Ms. Jolynn Parchen
Location State: IL Country: US
View the Interpretation Document
Response text:
Apr 26, 2005
Ms. Jolynn Parchen Reference No. 04-0285
Safety and Benefits Manager
Human Resources
The Field Museum
1400 S. Lake Sore Drive
Chicago, Illinois 70605-2496
Dear Ms. Parchen:
This responds to your letter dated December 17, 2004 regarding the Hazardous Materials Regulations HMR 49 CFR parts 171-180 as they apply to the shipment of museum artifacts preserved with arsenic dust. Specifically, you ask if shipments of artifacts treated with arsenical dust are not subject to the HMR. You provided information, as follows:
From the 1890s into thel94Os, natural history museums, like the Field Museum, used arsenical dust as a pesticide to help preserve certain artifacts in their collections. Generally, these artifacts are made of organic materials such as hides, feathers, fur or wood. The residue of this arsenical dust remains on the surface of treated artifacts.
The Merckoquant® Arsenic Test is used to determine whether or not the artifact has been contaminated with arsenic. Using the Merckoquant® Arsenic Test, the museum determined that the most contaminated artifacts tested at less than 0.003 grams per liter arsenical dust from 1 cm area swab. This is equivalent of 0.014 grams per square foot of arsenical dust on the entire artifact surface. For example, the largest contaminated object tested to date is a New Guinea mask of maximum dimensions 20’ x 4’x4’, having a surface area of 320 square feet. A total of 4.9 grams arsenical dust would be present on the surface area of the mask if the whole surface were equally contaminated.
The Field Museum receives numerous requests each year from other institutions to loan artifacts to them for research and public exhibition. For preservation reasons, artifacts that move in transportation are packed in multiple layers of impact, shock, and vibration absorbing materials. The custom-made crates are made of 5/8’ plywood and 1” by 4” wood battens that are lined with at least 2” thick planks of medium to high density closed cell polyester foam. Each artifact is in its own custom-made internal compartment that is made with lower density polyester foam and lined with Tyvek™ polyethylene sheet.
Under the HMR, tests to determine if a material meets the definition for a Division 6.1 (poisonous) material are found at § 173.132, which specifies oral, dermal or inhalation toxicity criteria. If a material does not meet the criteria for a Division 6.1 (poisonous) material or any other hazard class, it is not subject to the requirements of the HMR.
Although a residue of the arsenical dust remains on the surface of the artifacts, it is our opinion that the packaging you utilize for shipment of the artifacts is sufficient to mitigate the minimal hazard that may be present during transportation. Therefore, 5hipments of artifacts with surface residues of arsenical dust that are packaged as described in your letter are not subject to regulation under the HMR.
I hope this satisfies your inquiry. If we can be of further assistance, please contact us.
Sincerely,
John A. Gale
Chief, Standards Development
Office of Hazardous Materials Standards
172.101, 173.132