Laserfiche WebLink
DocuSign Envelope ID: ED6D46CC-2605-4COB-927B-6DEE507817B9 <br /> RECEIVED BY SJCEHD (EF) on 12/4/2019 <br /> C_; US ecology <br /> 17440 College Parkway,Suite 300, Livonia, MI 48152 <br /> 734.521.8000 734.521.8140 <br /> 12/3/19 <br /> Smart and Final Stores LLC <br /> 600 Citadel Dr <br /> Attn: Darryl Dinson <br /> Commerce, CA 90040 <br /> Subject: Hazard Classification of Aerosols <br /> Smart and Final is requesting information on how aerosols that may be defined as a pesticide by <br /> FIFRA can be packaged and shipped with other aerosols and classified as a DOT 2.1 flammable gas. <br /> In 49 CFR 171,8, the DOT defines an aerosol as "an article consisting of any non-refillable <br /> receptacle containing a gas compressed, liquefied or dissolved under pressure, the sole purpose of <br /> which is to expel a nonpoisonous (other than a Division 6.1 PGIII material) liquid, paste, or powder <br /> and filled with a self-closing release device allowing the contents to be ejected by the gas." Based <br /> on this definition and the precedence table found at 49 CFR 173.2a, the DOT views the hazard of <br /> the flammable gas as the primary hazard in transport, and unless the material exceeds the <br /> definition of a 6.1, PGIII, then it can be classified as a flammable gas aerosol. <br /> US Ecology has also surveyed many safety data sheets in classifying this material to determine how <br /> the manufacturer has performed this classification. Manufacturers of the products in question have <br /> classified the materials as a DOT hazard class 2.1 following DOT regulations. <br /> US Ecology appreciates Smart and Final's commitment to compliance and we look forward to <br /> assisting in any manner possible. <br /> Thank you, <br /> Bryan Schultz <br /> Environmental Program Manager <br /> Unequaled service.Solutions you can trust. <br /> USecology.com <br />