OSHA Hazard Information Bulletins
September 25, 1991
| MEMORANDUM FOR: |
REGIONAL ADMINISTRATORS |
| THROUGH: |
LEO CAREY
Director
Office of Field Programs |
| FROM: |
THOMAS J. SHEPICH
Director
Directorate of Technical Support |
| SUBJECT: |
Hazard Information Bulletin on the Classification of
Ammonium Perchlorate |
The San Francisco Regional Office brought to our attention a potential
problem due to the inconsistency among different authorities in the
classification of ammonium perchlorate (AP) as an oxidizer or as an
explosive. Since there are differences in the classification by different
Federal and State jurisdictions, the question of proper classification for
the purpose of safe handling, storage and transportation in the workplace is
at issue.
CHARACTERISTICS OF AP:
Ammonium perchlorate (NH(4)CLO(4)) is a white crystalline substance. It is
a powerful oxidizing material. It is stable in pure form at ordinary
temperature, but decomposes at a temperature of 150 degrees C or above. It
becomes an explosive when mixed with finely divided organic materials. AP
exhibits the same explosive sensitivity to shock as picric acid (Class A
explosive). Sensitivity to shock and friction may be great when contaminated
with small amounts of some impurities such as sulfur, powdered metals and
carbonaceous materials. AP may explode when involved
in fire.(1)
AP CLASSIFICATIONS:
OSHA Standards
29 CFR 1910.109(a)(3) is OSHA's definition of explosive. It references the
Department of Transportation (DOT) regulation, 49 CFR Chapter I, regarding
the classification of explosives.
Department of Transportation Standards
DOT classifies AP either as an oxidizer or high explosive under the DOT
standard 49 CFR 172.101 "Hazardous Material Table." This table is for
domestic uses and does not specify particle size for AP. DOT 49 CFR 172.102
"Optional Hazardous Materials Table" lists AP with average particle size
under 45 microns as explosive for the purpose of international shipping.
Current DOT regulations require the shipper to classify hazardous materials.
It is our understanding from DOT that if AP is intended to be used as an
explosive, or if the shipper has doubt that it could be explosive, the
shipper must send samples to either the Bureau of Mines (BOM) or the Bureau
of Explosives (BOE) for testing and classification. DOT has revised its
standards to require that for AP to be classified as an explosive, it must
meet the United Nations (UN) Tests and Criteria, Recommendation on the
Transportation of Dangerous Goods. The distinction between AP as
explosive and as oxidizer is based on test results. Laboratory testing is
required in making the classification determination. The revised DOT
standards will be effective on October 1, 1991. However, DOT has authorized
immediate compliance with the amended regulations.
Department of Defense (DOD)
DOD is authorized to classify military explosives. Commercial explosives,
however, must be classified and approved by DOT. DOD Hazardous Material
Classification Procedure is similar to the United Nations Classification
Procedure. UN classifies explosives as Class 1 materials. Under Class 1
there are six divisions:
Division 1.1 Substances and articles which have a mass explosion
hazard.
Division 1.2 Substances and articles which have a projection hazard
but not a mass explosion hazard.
Division 1.3 Substances and articles which have a fire hazard and
either a minor blast hazard or a minor projection
hazard or both, but not a mass explosion hazard.
Division 1.4 Substances and articles which present no significant
hazard.
Division 1.5 Very insensitive substances which have a mass
explosion hazard.
Division 1.6 Extremely insensitive articles which do not have a
mass explosion hazard.
The UN Class 5 materials are oxidizing substances and organic peroxides. The
following are Class 5 divisions:
Division 5.1 Oxidizing substances.
Division 5.2 Organic peroxides.
According to the DOD Explosives Safety Board, AP manufactured at 200 microns
has been tested and classified as UN Class 5, Division 5.1 oxidizer. The
U.S. Army currently classifies AP with particle size under 15 microns as
Class 1, Division 1.1 explosive. AP with particle size over 15 microns and
stored near explosive materials is classified as Class 1, Division 1.3
explosive. The Army classifies 200 microns AP as Class l, Division 1.4
explosive when it is located in an explosive area.
Bureau of Alcohol, Tobacco and Firearms (BATF)
In 1975 BATF published an explosive materials list which contained AP. Based
on industry and DOD test data received, BATF concluded in April, 1976 that AP
having nominal particle size less than 15 microns is an explosive material.
Before April, 1976, BATF used 45 microns as the cutoff.
State of Utah OSHA
The State of Utah OSHA considers AP to be an explosive material regardless
of its size. Utah defines explosive materials as "These include explosives,
blasting agents and detonators. The term includes, but is not limited to
dynamite and other high explosives, slurries, emulsions, water gels, blasting
agents, black powder, pellet powder, initiating explosives, detonators,
safety fuses, squibs, detonating cord, igniter cord, igniters, pyrotechnics,
pyrotechnic compositions, fireworks (special and Common), ammunition, propellent and propellent compositions."
CONCLUSION:
Since 1910.109(a)(3) references DOT regulations, OSHA must follow the most
current DOT classification of hazardous materials. Compliance with any other
Federal or State regulations may or may not be adequate for the purpose of
1910.109(a)(3) requirements.
RECOMMENDATIONS:
Our recommendations for the classification of AP are as follows:
1. AP is a Class 5.1 oxidizer unless the manufacturer classifies
it as a Class 1 material (explosive).
2. AP is an explosive if a sample is sent to BOM for testing
according to the UN test criteria for explosive, and was found to meet the
requirements as a Class 1 material and accepted by DOT. However, we
recommend that samples be taken only by individuals specifically trained to
handle potentially explosive materials.
REFERENCE:
1. NFPA 49-1975, Hazardous Chemical Data, Fire Protection Guide
on Hazardous Material, 1986.
Footnote (1) The Directorate of Technical Support issues
Hazard
Information Bulletins (HIBs) in accordance with OSHA Instruction CPL 2.65
to provide relevant information regarding unrecognized or misunderstood
safety and health hazards, and/or inadequacies of materials, devices,
techniques and engineering controls. HIBs are initiated based on information
provided by the field staff, studies, reports, concerns expressed by safety
and health professionals, employers and the public. Information is compiled
based on a comprehensive evaluation of available facts, literature and in
coordination with appropriate parties. HIBs do not necessarily reflect OSHA
policy. (Back to Text)
|
Back to Top
Printing Instructions