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From: Monona Rossol <0000030664c37427-dmarc-request**At_Symbol_Here**LISTS.PRINCETON.EDU>
Subject: Re: [DCHAS-L] EXTERNAL: Re: [DCHAS-L] Unfamiliar Material [MOT Exemption Opportunity]
Date: Tue, 21 Feb 2017 15:03:55 -0500
Reply-To: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**PRINCETON.EDU>
Message-ID: 15a6245f0e1-4fcf-21ff**At_Symbol_Here**webprd-a28.mail.aol.com
In-Reply-To <08083675128f401e869b8e0fac949646**At_Symbol_Here**TTCExchange.TankTrailerCleaning.com>
I have all of the good advice in a file and plan to include a little awareness module on this in our next hazcom.
Monona Rossol, M.S., M.F.A., Industrial Hygienist
President: Arts, Crafts & Theater Safety, Inc.
Safety Officer: Local USA829, IATSE
181 Thompson St., #23
New York, NY 10012 212-777-0062
-----Original Message-----
From: Mark Ellison <Mark**At_Symbol_Here**TANKTRAILERCLEANING.COM>
To: DCHAS-L <DCHAS-L**At_Symbol_Here**PRINCETON.EDU>
Sent: Tue, Feb 21, 2017 1:17 pm
Subject: Re: [DCHAS-L] EXTERNAL: Re: [DCHAS-L] Unfamiliar Material [MOT Exemption Opportunity]
Monona,
Vincent and George have succinctly communicated everything I would have said earlier, although I can only speak to IATA with regards to international shipping/travel.
When I was a contractor, I ran into this situation repeatedly with my crews and had to re-train and reinforce that training on an all to regular basis.
Monona -
I was out of the office for several days. You may already have had responses to the packaging and shipping dilemma.
Good news: There is a floor level of consistency between DOT, the International Air Transport Association (IATA) [applies to ALL shipments by air, both international and domestic,
and the International Maritime Organization (IMO). All three are derived from the UN Recommendations for the Safe Transport of Dangerous Goods (the Orange Book).
Bad news: The devil is in the details. Whoever is going to sign the shipping documents needs to demonstrate they have received training in general awareness, safety, security,
and function-specific operations.
The materials of trade (MOT) exceptions applies only to domestic transportation. The regulations are published at 49 CFR 173.6. It is not under copywrite protection and is
available on line. IATA and IMO regulations are copywrite protection.. MOT applies to:
Flammable Liquids - Class 3 (flammable liquids)
Corrosive materials - Class 8 (both liquids and solids and both acids and bases)
Miscellaneous Dangerous Goods - Class 9 (both liquids and solids)
Flammable solids - Division 4.1
Oxidizers - Division 5.1
Organic peroxides - Division 5.2
Poisons - Division 6.1 (both liquids and solids)
Pyrotechnic materials are in Class 1 (probably Division 1.4) are NOT subject to MOT exceptions.
Then life gets complicated. With each Class there are Packaging Groups (I, II, and III) that describe the degree of risk. Introduction to PG: Diethyl ether is Class 3, PG
I; gasoline is Class 3, PG II; diesel is in Class 3, PG III. Lithium batteries (metallic and polymer) are in a world by themselves and there were major changes in DOT, IATA, and IMO that took effect January 1, 2017. They are all Class 9 but specific packaging
and labeling requirements are based on the amount of lithium (metallic) or the Watt-hours (polymers).
This is long enough. Whoever is offering the materials the materials for transportation must do a fair amount of reading. I'll bet a cheap dinner that your folks in theater
arts are no worse than shipyard workers - civil service, active duty, contractors - who are clueless until they get to the new work site and the "chemicals" are sitting at a trucking warehouse or air cargo office hundreds of miles away.
If you or they are interested, contact us directly (phone is probably better that e-mail) to talk about details.
George C. Walton, CHMM
Reactives Management Corporation
1025 Executive Blvd., Suite 101
Chesapeake, VA 23320
(757) 436-1033
Brilliant. Thanks so much. There still are several big problems I will need to iron out. For example, these paints have been mixed with other ingredients and colorants
-- many not traditional -- in order to get the exact color and texture needed for a particular effect on the set. So the original container is not really a possibility. And even if the label on the original base of the paint were kept, the ingredients are
not accurately represented by the label.
Training is also a big problem. We usually work with the Teamsters for along hauls, but sometimes it is other union workers.
As for the thread, I thank EVERYONE who participated. I have learned a ton. And now I have a pathway to get this worked out.
THANKS to all.
Monona Rossol, M.S., M.F.A., Industrial Hygienist
President: Arts, Crafts & Theater Safety, Inc.
Safety Officer: Local USA829, IATSE
New York, NY 10012 212-777-0062
Based on the description provided by Monona, and dependent on the products, packagings and quantities used, it seems like the USDOT "Materials of Trade" exception
could be invoked to demonstrate that hazardous materials are being properly transported. Here is the link to a USDOT pamphlet that provides general MOT requirements:
=B7
The MOT exemption typically requires the use of fairly =E2=80=98benign' products that are their original container. The MOT is targeted towards the tradesman who needs to transport
several gallons of paint to a work site and use it to paint a building. For example, a worker could go to Home Depot and pick up some flammable varnish and transport it to the house he's working on- Thus, the MOT exemption can probably
not be utilized for your pyro shipments.
=B7
The MOT exemption is for highway mode only (truck) - Air/Rail/Ship (and international) shipments are not allowed
=B7
The containers should bear the appropriate HazCom information. The use of the =E2=80=98secondary containers' that was described should probably be reviewed to ensure that "-a package
of equal or greater strength and integrity" has been used. These containers would also need to be in good condition, closed and display the appropriate HazCom labeling during transport.
=B7
While not tracked to the same extent as other DOT requirements, you would still need to provide appropriate training is in place to demonstrate conformance to DOT MOT transportation
and OSHA HazCom requirements.
=B7
While not directly germane, it seems like your industry may also have labor-related union issues. That is, workers who =E2=80=98transport' chemicals as part of a production unit may
be doing the work of a different class (i.e., "Drivers") which could lead to grievances, etc. Suggest that these types of conflicts be considered so that mutual cooperation is achieved.
I understand that this topic has veered off from the original discussion - recommend a new =E2=80=98string' be started if others want to comment.
Lockheed Martin Aeronautics Company
Environment, Safety & Health - Palmdale 661-572-4329
There are obviously labeling for HazCom issues for what folks carry in there personal vehicles but.......the bigger issue I see is DOT requirements for transport of hazardous chemicals over the open roadways regulated
by DOT. We got to the point of NOT allowing researchers to carry hazardous chemicals in personal vehicles. In a chemical company we had lots of researchers, sales, marketing and technical folks who wanted to carry hazardous chems in personal vehicles. There
is special DOT requirements for this. We got to the point where we had our chemical delivery trucks carrying all chemicals locally. (Those vehicles were DOT registered and the drivers knew how to handle the paperwork). Anything outside of local delivery
was handled by delivery companies that had the delivery equipment and annual training for their employees.
Aaron Chen, MPH, CIH, FAIHA
Sent from Aaron's iPhone.
You sound like you also know what you are doing. Maybe you can refer me to someone who would be able to help scenic artists get their road box liquid paints, dyes,
solvents and other chemicals properly labeled for transport. Almost none of these will be in their original containers. They are paints that have been altered and mixed to the colors on a particular set design. These usually are steamer trunk-sized boxes
full of all the stuff they will need.
Mostly the crisscross the US from Coast to Coast, but occasionally go across the big and little ponds and some have had these materials confiscated.
And then there are pyrotechnic road boxes, Oy.
Monona Rossol, M.S., M.F.A., Industrial Hygienist
President: Arts, Crafts & Theater Safety, Inc.
Safety Officer: Local USA829, IATSE
New York, NY 10012 212-777-0062
-----Original Message-----
From: Mark Ellison <Mark**At_Symbol_Here**TANKTRAILERCLEANING.COM>
To: DCHAS-L <DCHAS-L**At_Symbol_Here**PRINCETON.EDU>
Sent: Fri, Feb 17, 2017 10:13 am
Subject: Re: [DCHAS-L] Unfamiliar Material
As a follow-up, the manufacturer called and helped clear up the confusion on our end. Turns out, this material has not been shipped, but the hauler was trying to get pricing in place to quote to the manufacturer for turnkey service, the hauler being my customer.
The manufacturer is putting me in touch with the product "steward", so I can determine safe work practices, equipment needs, and disposal options of heels and rinsates.
Thank you to everyone in this list for commenting on and off line. It is a great feeling to know that I have this outstanding resource available to me to help in my life long journey to provide health and safety guidance to my folks.
Mark Ellison
-----Original Message-----
From: ACS Division of Chemical Health and Safety [mailto:DCHAS-L**At_Symbol_Here**PRINCETON.EDU]
On Behalf Of TILAK CHANDRA
Sent: Wednesday, February 15, 2017 1:11 PM
To: DCHAS-L**At_Symbol_Here**PRINCETON.EDU
Subject: Re: [DCHAS-L] Unfamiliar Material
Aromatic compound with a trifluoromethyl substitution. From SciFinder.
Tilak
1417782-28-5
Structure:
AS Registry Number 1417782-28-5
C15 H10 Cl F3 O2
Ethanone, 1-[4-(4-chlorophenoxy)-2-(trifluoromethyl)phenyl]-
Molecular Weight
314.69
Boiling Point (Predicted)
Value: 372.5 =B142.0 =B0C | Condition: Press: 760 Torr Density (Predicted)
Value: 1.327 =B10.06 g/cm3 | Condition: Temp: 20 =B0C Press: 760 Torr Other Names
• 1-[4-(4-Chlorophenoxy)-2-(trifluoromethyl)phenyl]ethanone
• 1-[4-(4-Chloro-phenoxy)-2-trifluoromethyl-phenyl]ethanone
Notes
1) chemoselective, Grignard reaction, Reactants: 3, Reagents: 3, Catalysts: 1, Solvents: 3, Steps: 2, Stages: 4, Most stages in any one step: 3 References Process for the preparation of substituted phenoxyphenyl ketones Quick View By Vogelbacher, Uwe Josef
et al From PCT Int. Appl., 2015091045, 25 Jun 2015
-----Original Message-----
From: ACS Division of Chemical Health and Safety [mailto:DCHAS-L**At_Symbol_Here**PRINCETON.EDU]
On Behalf Of davivid
Sent: Wednesday, February 15, 2017 12:50 PM
To: DCHAS-L**At_Symbol_Here**PRINCETON.EDU
Subject: Re: [DCHAS-L] Unfamiliar Material
A google search on docetaxel pulls up a wikipedia entry having that CAS number, but the structure does not correspond to the name on the SDS.
D
On 15/2/17 9:54 AM, Frankie Wood-Black wrote:
> The CAS No pulls this up in the Sigma Aldrich Catalog - Docetaxel
>
> Does not look like it is on the TSCA Inventory
>
> *Frankie Wood-Black, Ph.D., REM, MBA*
> *Principal - Sophic Pursuits*
> *NOTE - ADDRESS CHANGE - Mailing Address - PO Box 433, Tonkawa, OK
> 74653* *email address fwoodblack90**At_Symbol_Here**gmail.com <fwoodblack**At_Symbol_Here**gmail.com>*
> *or fwblack**At_Symbol_Here**sophicpursuits.com <fwblack**At_Symbol_Here**sophicpursuits.com>*
>
> *580-761-3703*
>
> On Wed, Feb 15, 2017 at 10:37 AM, Mark Ellison
> <Mark**At_Symbol_Here**tanktrailercleaning.com
>> wrote:
>
>> All,
>>
>>
>>
>> I am stymied here. I have a customer who presented a vessel that
>> previously contained a material with the CAS number 1417782-28-5 for
>> cleaning. The chemical name on the SDS is "Ethanone,
>> 1-[4-(4-chlorophenoxy)-2(trifluoromethyl)phenyl]-". I tried to look
>> it up on the CAS site and got "No Results". I called the
>> manufacturer and they couldn't find the product either by CAS number or product number.
>> They said they would get back to me. Any suggestions would be
>> greatly appreciated. I just want to know if I can safely wash this
>> vessel without harming my employees, the environment, or the downstream POTW. Thanks!
>>
>>
>>
>> Mark Ellison
>> --- This e-mail is from DCHAS-L, the e-mail list of the ACS Division
>> of Chemical Health and Safety. For more information about the list,
>> contact the Divisional secretary at secretary**At_Symbol_Here**dchas.org
>
> ---
> This e-mail is from DCHAS-L, the e-mail list of the ACS Division of Chemical Health and Safety.
> For more information about the list, contact the Divisional secretary
> at secretary**At_Symbol_Here**dchas.org
>
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