49CFR/DOT: ICAO/IATA/A.I.R.: UN3334, Aviation Regulated Liquid, n.o.s. (1,3,4-TrimercaptoStinky), 9, III. IMO/IMDG: Not Dangerous Goods

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1 A: You sell a product that has a very powerful, foul odor, but no other hazardous properties. Your msds software is pre- set to three sets of transportation regulations. Two are populated as follows: 49CFR/DOT: ICAO/IATA/A.I.R.: UN3334, Aviation Regulated Liquid, n.o.s. (1,3,4-TrimercaptoStinky), 9, III IMO/IMDG: Not Dangerous Goods What are your options for the 49CFR/DOT classifications? (Hint: 49CFR (b) and UN3334) Which factors will go into making your decision about which one to use? (Hints: which modes does your company ship most often, which modes do your customers re- ship most often, how competent or confused can your warehouse staff be, how does Sec. 14 interface with your shipping system, which classification opens you up to lawsuits, what does your carrier expect, etc )

2 B. Write a multiple choice test question for msds authors who are taking a Section 14 training class. The question must be about an ultra- fast acting (~10 seconds), ultra- short duration (~3-5 minutes) general anesthetic with no other hazardous properties.

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4 A.. Your company ships giant- sized mercury thermometers to middle schools and high schools for use in meteorology and other science classes. Each thermometer has 3 ml of mercury (40 g). Your company only ships individual thermometers, and only by ground, and only domestically. What are your options for Section 14 49CFR/DOT classification? (Hint: UN3506, or 49CFR (b)). Which option will you choose, and why? (Hint: HazMat fees, ease of operations, no training, etc )

5 B. Business booms, and your company begins to also ship the giant thermometers in cases of 12. Your (Hint: poorly educated) warehouse staff prefers (Hint: needs) just one transport classification. You still only ship ground, and only domestically. Role play a discussion (Hint: argument) amongst your msds Author, VP of Finance, VP of Legal, and Warehouse Shipping Supervisor about which transport classification will get used when (Hint: case vs. each), and what your section 14 will or will not be revised to show. (Hint: Re- read all of 49CFR (b)(2) & (b)(6), 49CFR Appendix A, 5 th grade math)

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7 A. Live organisms don t normally require an msds, but your carriers keep asking for them. When your medical laboratory & hospital related company starts creating msdss for certain organisms, such as Mycobacterium Tuberculosis and Escherichia Coli, sometimes the Section 14 classification doesn t match the package marks & labels, yet you re always in compliance. Explain how this is possible. (Hint: First eight words of 49CFR (a)(1)(i), Category A indicative list)

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9 B. Your seafood supply company ships live crabs (not the microorganisms, but the macroorganisms) all over the globe, next day air. Each full moon, plus & minus 2 days, one type of crab secretes large quantities of pheromones that rapidly corrode aluminum. When your carriers and customers demand msdss, what will you put in Section 14, and why? (Hint: free form explanation? Disclaimer? Something else?)

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11 A. Your US- based company sells, domestically, a product that has no GHS hazards, but does react rapidly with water to release large amounts of toxic (poisonous) gas. What do you put in Section 14? (Hint: 49CFR (c)) How do you explain to your carrier, to OSHA enforcement, to DOT enforcement, to your customer, why Section 14 doesn t match a gharmonizeds warning in any other section of your msds?

12 B. Your company begins to sell this product across the Atlantic to Europe. Draw and describe your potential exposures for various classifications on both sides of the Atlantic. What do you end up putting in Section 14? (Hint: 49CFR (c)) HM compliant? Lawsuits post- exposure HM compliant? Lawsuits post- exposure Classification 1 Classification 2 DG compliant? Lawsuits post- exposure DG compliant? Lawsuits post- exposure

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14 A. Your liquid product msds has a flame pictogram, and a written assessment of Category 1. Yet your Section 14 in the same msds does NOT declare Class 3 as either a primary or a subsidiary hazard. Why not? How could this be? (Hint: OSHA flame pictogram assignment shown below) (Hint: 49CFR (b)(1), UN2845 & UN3194)

15 B. Role play an explanation (discussion) with the new, inexperienced, lightly trained, air carrier acceptance agent who challenges your non- 3 classification. (Hint for carrier: H=harmonized; Flame + liquid = Class 3) (Hint for shipper: eventually fax copies from hints for part A of this exercise)

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17 A. Sandersonium, a new, miraculous, hair- growing product you ve discovered, has no oral nor dermal toxicity. The volatility (saturated vapor concentration) of Sandersonium is 10 ppm. But, if heated sufficiently, enough Sandersonium can be evaporated (turned to gas) to test an LC50 (rat) of 100 ppm/1h (~ mg/l/4hours). What is the GHS toxicity category? (Hint: See OSHA GHS tox assignment table, below) Is Sandersonium 6.1 by animal data, and if so, at which PG? (Hint: 49CFR Figure 1 or 49CFR (a)(2)(i))

18 B. Your msds author, a PhD toxicologist, want to enter a compromise Section 14 entry for Sandersonium, as 6.1 PG III. Can this be justified or not? Discuss. (Hint: 49CFR (a) wording prior to (a)(1))

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20 A. Your brand new fuel additive product, The GACK, (not dee- GAC, thee GACK), bears a red & white, stripey DG/HazMat label with the words Flammable Solid on it. Yet, The GACK s msds has a bomb pictogram and says your product is a liquid. The same person who does your transportation classifications writes your msdss. Do you fire her? Why not? How could she be right? (Hint: OSHA GHS bomb pictogram assignment list, 49CFR (a)(2), UN3221, UN3231, et al)

21 B.. Two of the three subdivisions of Division 4.1 can be liquids, yet the 4.1 label & placard say Flammable Solid. Propose solution(s), even partial, for this contradiction. (Hints: 49CFR (a) Reactive Materials 4.4 & 4.5 New label Just use pictogram???)

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23 A.. Using old- fashioned pollination control techniques, but not any molecular biology techniques, your botanists have created a new type of very flavorful, ultra- hot pepper plant. It is not a GMO. Come up with a name for these peppers. (Hint: Maybe come up with several names and let the audience vote?)

24 B.. Extracts from the new peppers are dried and milled. Small drums of the powered solid are shipped to every different maker of self- defense sprays, so they can experiment with switching to your pepper extract. The extract is not corrosive, not toxic per animal data, and not a readily combustible solid per burning rate tests. But it is very irritating, to both skin and eyes, especially in high concentrations at close range. Your msds gives it the Exclamation Point pictogram. At this time, this extract is not in a form suitable for retail sale. Find two arguably compliant transport classifications for Section 14. Argue the merits of each. (Hint: 49CFR (a)(2)) (Hint: package costs, rejections, HazMat fees, post- exposure lawsuits if under classified, confusion over pictogram versus transport label, etc )

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