UN 3219 Nitrite solutions

IC1967:
Apologies, I will quote from the 2017 edition.

3.1.3.2 A solution or mixture meeting the classification criteria of ADR composed of a single predominant
substance mentioned by name in Table A of Chapter 3.2 and one or more substances not subject to
ADR or traces of one or more substances mentioned by name in Table A of Chapter 3.2, shall be
assigned the UN number and proper shipping name of the predominant substance mentioned by name
in Table A of Chapter 3.2 unless:
(a) The solution or mixture is mentioned by name in Table A of Chapter 3.2;
(b) The name and description of the substance mentioned by name in Table A of Chapter 3.2
specifically indicate that they apply only to the pure substance;
(c) The class, classification code, packing group, or physical state of the solution or mixture is
different from that of the substance mentioned by name in Table A of Chapter 3.2; or
(d) The hazard characteristics and properties of the solution or mixture necessitate emergency
response measures that are different from those required for the substance mentioned by name
in Table A of Chapter 3.2.
Qualifying words such as “SOLUTION” or “MIXTURE”, as appropriate, shall be added as part of the
proper shipping name, for example, “ACETONE SOLUTION”. In addition, the concentration of the
mixture or solution may also be indicated after the basic description of the mixture or solution, for
example, “ACETONE 75% SOLUTION”.

My interpretation of this is as follows:

The only substances in the IBCs are Sodium Nitrite (the ‘single predominant substance mentioned by name in Table A of Chapter 3.2’) and water (a ‘substance not subject to ADR’).

The UN number and Proper Shipping Name of the predominant substance (UN1500 SODIUM NITRITE) cannot be used for this solution since the conditions of 3.1.3.2 (c) are satisfied in at least two ways - namely, the physical state of the solution (liquid) is different from the substance (solid) mentioned in Table A, and consequently the classification code can no longer be OT2 Oxidizing Toxic Solid and so must change to either O1 Oxidizing Liquid or OT1 Oxidizing Toxic Liquid, assuming that the solution is concentrated enough to possess oxidizing/toxic properties.
In addition, 3.1.3.2 (a) appears to apply since the seemingly more appropriate UN3219 NITRITES, INORGANIC, AQUEOUS SOLUTION, N.O.S. is listed in Table A of Chapter 3.2.

Hi IC1967,

Thanks for the extra info.

I can see your thinking, but with the info to hand so far, I now see this job a little differently.

Since we’re both using the same books (ADR 2017) we can probably dispense with quoting chunks of text.

Since we’re dealing with the classification of a waste, I suggest that we follow the procedure at ADR 2017 2.1.3, which indicates that we should use a collective entry.

Using the info to hand so far, I now get it to this…

UN 3099 WASTE OXIDISING LIQUID, TOXIC, N.O.S., (contains sodium nitrite), 5.1 (6.1) PGIII

References:
ADR 2107 2.1.3, 2.2.51.3, 3.2.1 table ‘A’, 3.3 SP 274 [refers to 3.1.2.8] and 5.4.1.1.3

:bulb: So that those involved don’t go to disproportionate effort, a glance at ADR 2107 2.1.3.5, 2.1.3.5.1 and 2.1.3.5.2 may be helpful.