We have a customer who wants to dispose of IBCs of waste Sodium Nitrite solution of varying concentrations -what is the concentration threshold that the Sodium Nitrite needs to be where it has to be consigned as UN 3219 NITRITES, INORGANIC, AQUEOUS SOLUTION, N.O.S., Class 5.1 oxidizing?
IC1967:
We have a customer who wants to dispose of IBCs of waste Sodium Nitrite solution of varying concentrations -what is the concentration threshold that the Sodium Nitrite needs to be where it has to be consigned as UN 3219 NITRITES, INORGANIC, AQUEOUS SOLUTION, N.O.S., Class 5.1 oxidizing?
Hi IC1967,
There is no “concentration threshold” for this substance.
Correctly written for your paperwork, the word “WASTE” needs to be inserted in between the UN number and the Proper Shipping Name :
UN 1500 WASTE SODIUM NITRATE SOLUTION, 5.1 (6.1), PGIII (E)
UN 1500 does not turn into the substance you mentioned because of its concentration.
The only time that its UN number (and name) changes is if there are any other substances added in to the solution.
From the info you’ve given, it looks like you’re good to go, but it is UN 1500.
But can UN1500 be used for a solution of Sodium Nitrite?
ADR 3.1.3 states that:
3.1.3 Mixtures and solutions containing one dangerous substance
3.1.3.1 A mixture or solution containing a dangerous substance identified by name in the Dangerous Goods List and one or more substances not subject to these Regulations shall be treated according to the requirements given for the dangerous substance provided that the packaging is appropriate to the physical state of the mixture or solution, unless:
(a) The mixture or solution is specifically identified by name in these Regulations; or
(b) The entry in these Regulations specifically indicates that it applies only to the pure substance; or
(c) The hazard class, physical state or packing group of the solution or mixture is different from that of the dangerous substance; or
(d) There is significant change in the measures to be taken in emergencies.
With regards to (c) and (d), the physical state obviously changes as Sodium Nitrite is a solid whereas a solution is a liquid, the emergency procedures would change as well as you’d be dealing with a mobile liquid rather than a solid.
So would UN 3219 not be the most appropriate?
IC1967:
But can UN1500 be used for a solution of Sodium Nitrite?
Hi IC1967,
The answer to that question is YES.
Does your customer know exactly what was put into the sodium nitrite to make it a “solution” that you mentioned in your OP please?
From the info you’ve given so far ( = no other substance mentioned,) I’m sticking with my first answer.
IC1967:
So would UN 3219 not be the most appropriate?
UN 3219 would only need to be used when there is/are some other named dangerous substance(s) in the solution or mixture, which would then give rise to some extra requirements. For now, you have given no indication of this.
I’d also like to ask what year is on the front cover of the ADR book that you’re quoting from please?
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.
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
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.