Document 0BD74r50ywZyJrRmXp7koVNR
Inspection Entry Date/Time Inspection Exit Date/Time
Regulatory Program Type of Inspection
EPA REGION 6 Enforcement Division
INSPECTION REPORT
06/26/2024 09:50 AM (CT)
Announced: No
06/26/2024 10:59 AM (CT)
Access: Granted
RCRA Focused Compliance Inspection (FCI)
Facility or Site Name Facility/Site Identifier Facility/Site Physical Address City, State, Zip Code County/Borough Generator Status NAICS Type of Operation
Geographic Coordinates
Ports America Corporation TXR000078378 575 Pete Schaff Blvd #206 Freeport, TX 77541 Brazoria County Very Small Quantity Generator (VSQG) 488320 Ports America Corporation serves as stevedores for various tenants around the port. 28.9444, -95.346
Additional Persons Participating in Inspection:
Name
Title
Organization
Elizabeth Pham
Inspector
EPA REGION 6
Erin Young-Dahl
Inspector
EPA REGION 6
Neil Rapp
Contractor
Eastern Research Group (ERG)
Email Pham.Elizabeth@epa.gov YoungDahl.Erin@epa.gov Neil.Rapp@erg.com
Lead Inspector: Vince Damiano
Vincent Damiano ERG
Digitally signed by Vincent Damiano Date: 2024.08.27 13:50:15 -04'00'
Vince.Damiano@erg.com
Phone (214) 665-8354 (214) 665-3166 (480) 450-6517
(703) 633-1732
Page 1 of 4
Ports America Corporation
Inspection Date: 06/26/2024
SECTION I - INTRODUCTION
Site Entry and Purpose of the Inspection
The Port Freeport and surrounding facilities were selected for inspection based on an Environmental Justice and Regional initiative to evaluate facilities at ports receiving or transporting Resource Conservation and Recovery Act (RCRA)-regulated hazardous wastes, and/or have an International Convention for the Prevention of Pollution from Ships (MARPOL) Annex V Certificate of Adequacy (COA) issued by the U.S. Coast Guard (USCG).
This report is based on information supplied by the facility representatives, inspector observations, port related facilities, and records including photographs taken (see Appendix 1), verbal or written statements made during or after the on-site inspection, and/or materials shown, demonstrated, or submitted to the EPA during or after the on-site inspection. In addition, information gathered prior to or after the inspection from a review of EPA, State, and public records may be included in this report.
Attendees
Title/Organization Lead Inspector/ Contractor/ERG RCRA Inspector/ Contractor/ERG Inspector/Enforcement Officer/EPA Region 6 Inspector/Enforcement Officer/EPA Region 6
Name Vince Damiano
Phone
Email
(703) 633-1732 Vince.Damiano@erg.com
Opening Conf.
Yes
Closing Conf.
Yes
Neil Rapp
(480) 450-6517 Neil.Rapp@erg.com
Yes
Yes
Elizabeth Pham (214) 665-8354 Pham.Elizabeth@epa.gov Yes
Yes
Erin Young-Dahl (214) 665-3166 YoungDahl.Erin@epa.gov Yes
Yes
Facility General Description
Tenant/Area Ports America Corporation
Inspection Date
06/26/24
Process Description Ports America Corporation (Ports America) unloads cargo from ships for other companies at Port Freeport docks. It uses its own trucks and forklifts but operate cranes owned by Port Freeport. Ports America does maintain a MARPOL COA but does not remove any waste from ships.
Area of Concern
Yes
Page 2 of 4
Ports America Corporation SECTION II - OBSERVATIONS
Inspection Date: 06/26/2024
Tenant: Ports America Corporation
Section: 2.1
Date: 06/26/24, 09:50 AM Contains AOC: Yes Contains CBI: No
Lead Inspector: Vince Damiano Attendees: Scott Bowman (Terminal Manager), William Barrett (Safety Manager)
Ports America is located within Port Freeport and operates as a stevedore for multiple tenants within the port. Ports America uses Port Freeport owned cranes to load and offload cargo for its clients, while operating its own fleet of forklifts and trucks to move the cargo within the port. The company mainly operates at Docks 2, 5, 7, and 8. Ports America does maintain a MARPOL COA. Mr. Bowman stated Ports America does not remove any waste from ships; it only removes cargo. Ports America is registered with the EPA as a VSQG (TXR000078378).
Mr. Bowman explained Ports America does not generate any hazardous waste but mainly generates used oil, universal waste, and spent aerosol cans in its maintenance shop. The inspection team conducted a visual inspection of Ports America's maintenance area. The inspection team observed a full 55-gallon drum of used oil that was not properly labeled as `Used Oil' inside secondary containment (see Appendix 1 - Photo 1) [AOC #1: Ports America did not clearly label containers used to store used oil with the words "Used Oil." - 40 CFR 279.22 (c)(1)]. Next to the used oil drum, the inspection team observed a full 55-gallon drum of "Aerosol Can Waste" where Ports America drains liquid waste from punctured Brakleen aerosol cans (see Appendix 1 - Photo 2). When asked if there was a waste determination for the waste aerosol liquid, Ports America personnel stated that they did not know how the waste was characterized. [AOC #2: Ports America did not make a waste determination on the waste aerosol liquid at the point of generation. - 40 CFR 262.11(a)]. The inspection team also observed a solvent parts washer in the maintenance shop that is managed by a thirdparty, Safety Kleen.
The inspection team did not observe any other apparent AOCs at the time of the inspection. A closing conference was conducted at approximately 11:00 PM with Ports America personnel. The AOCs were communicated during the closing. Following the inspection, Mr. Bowman provided the inspection team with a waste determination for the waste aerosol liquid; based on the content of the Brakleen aerosol waste being disposed of in the drum, it was determined to be a hazardous waste (see Appendix 2). Mr. Bowman stated as a VSQG, Ports America would make sure the waste was appropriately labeled and managed. He added that disposal documentation for the waste would be maintained when it occurs, and that disposal of this waste stream has never occurred before. Mr. Bowman also provided a photograph of the 55-gallon drum of used oil properly labeled (see Appendix 3).
Page 3 of 4
Ports America Corporation
Inspection Date: 06/26/2024
SECTION III - RECORDS REVIEW
No RCRA-regulated records were reviewed during this focused onsite inspection.
SECTION IV - AREAS OF CONCERN
The presentation of Area(s) of Concern does not constitute a formal compliance determination or violation. Tenant: Ports America Corporation
AOC #1 - Ports America did not clearly label containers used to store used oil with the words "Used Oil."
Citation: 40 CFR 279.22 (c)(1)
Section: 2.1
AOC #2 - Ports America did not make a waste
Citation: 40 CFR 262.11(a)
determination on the waste aerosol liquid at the point
of generation.
Section: 2.1
SECTION V - FOLLOW UP
Follow-Up Any facility follow-up items are as discussed in the observations in Section II. Documents or files provided by the facility were transmitted via email and included responses to AOCs or provision of documents requested.
Communication Log
During and after the inspection, additional information was emailed to EPA including: 1. 06/28/24 Ports America email - Scott Bowman responded to the AOCs found; providing a waste determination and used oil label correction photograph.
SECTION VI - LIST OF APPENDICES Appendix 1. Photograph Log Appendix 2. Ports America 06/26/24 Waste Determination Response Appendix 3. Photograph of Labeled Used Oil
Page 4 of 4
APPENDIX 1. PHOTOGRAPH LOG
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Location: Ports America City: Freeport
Photo No. 1 County/Parish: Brazoria
State: Texas
Photo File Name: DSCN7384 Date of Photo: 06/26/2024 Time of Photo: 11:29 hrs. Photographer: Vince Damiano Description: A 55-gallon container of used oil in Ports America's maintenance shop not properly labeled.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Location: Ports America City: Freeport
Photo No. 2 County/Parish: Brazoria
State: Texas
Photo File Name: DSCN7385 Date of Photo: 06/26/2024 Time of Photo: 11:29 hrs. Photographer: Vince Damiano Description: A full 55-gallon container of aerosol can waste containing Brakleen fluid in Ports America's maintenance shop.
APPENDIX 2. PORTS AMERICA 06/26/24 WASTE DETERMINATION RESPONSE
RE: Follow-up from EPA Visit 6/26
Scott Bowman <scott.bowman@portsamerica.com>
Fri 6/28/2024 1:28 PM To:Neil Rapp <Neil.Rapp@erg.com>;Kelli Hardesty <Kelli.Hardesty@portsamerica.com> Cc:Vince Damiano <Vince.Damiano@erg.com>;Young-Dahl, Erin <YoungDahl.Erin@epa.gov>;Pham, Elizabeth <Pham.Elizabeth@epa.gov>
2 attachments (981 KB) Brakleen SDS.pdf; 741204890.jpg;
CAUTION: Don't open links or attachments unless you recognize the sender and know they are safe. Good Morning Neil,
Thank yall for visiting the site earlier this week.
Attached is the SDS for Brakleen, which can be provided to EPA in the response. See below for proposed response and let me know if there are further suggestions.
A hazardous waste determination for the aerosol can waste. The aerosol can waste drum contains only Brakleen fluid from the drained aerosol cans. Attached is the SDS. Based on the composition of the Brakleen fluid, the acetone and toluene would classify this as a non-acute hazardous waste based on listing. As a Very Small Quantity Generator (VSQG), we will continue to manage it appropriately. A label will be placed in an observable location to identify the contents of the drum, as well as other necessary information associated with hazardous waste labeling.
Shipping documentation for the last time Ports America disposed of aerosol can waste. Ports America has not disposed of the aerosol can waste to-date. As a VSQG, Ports America will continue to evaluate accumulation quantity limits allowed for VSQG (i.e., < 2,220 lbs). When disposal does occur, Ports America will use a TSDF who is licensed to manage and dispose of hazardous waste (e.g., Clean Harbors, etc.) and documentation will be maintained.
Please let me know if I can assist any further.
Best Regards,
Scott Bowman Terminal Manager - Freeport Ports America M. 281-667-6583 Website: https://freeport.portsamerica.com/
From: Neil Rapp <Neil.Rapp@erg.com> Sent: Wednesday, June 26, 2024 4:10 PM To: Scott Bowman <scott.bowman@portsamerica.com> Cc: Vince Damiano <Vince.Damiano@erg.com>; Young-Dahl, Erin <YoungDahl.Erin@epa.gov>; Pham, Elizabeth <Pham.Elizabeth@epa.gov> Subject: Follow-up from EPA Visit 6/26
Hi Scott, Thank you for your assistance this afternoon. I am following up with a list of items and notes from our inspection today. We would like you to send us: A hazardous waste determination for th
Appendix 2 Page 1 of 12
sophospsmartbannerend
Hi Scott, Thank you for your assistance this afternoon. I am following up with a list of items and notes from our inspection today. We would like you to send us:
A hazardous waste determination for the aerosol can waste. Shipping documentation for the last time Ports America disposed of aerosol can waste. Pictures of any responses to the areas of concern we communicated to you today. Please send the requested information to me and the persons copied on this email within two weeks. In addition, please see below a list of initial areas of concern that we noted today: Unlabeled 55-gallon drum of used oil (Attached picture of correct labeling) Thanks again for your time and please let us know if you have any questions or concerns. Regards,
Neil Rapp, P.E.
Senior Engineer Cell: 480-450-6517 neil.rapp@erg.com
IMPORTANT: This email and any files transmitted with it are confidential and intended solely for the use of the individual or entity to whom they are addressed. If you have received this email in error, please notify the sender immediately and delete the message. If you are not the named addressee, you should not disseminate, print, distribute, or copy this email without prior consent of the sender.
Appendix 2 Page 2 of 12
SAFETY DATA SHEET
1. Identification
Product identifier
Brakleen Brake Parts Cleaner
Other means of identification Product code
05151
Recommended use
Brake parts cleaner
Recommended restrictions
None known.
Manufacturer/Importer/Supplier/Distributor information
Manufactured or sold by:
Company name Address
Telephone General Information Technical Assistance Customer Service 24-Hour Emergency (CHEMTREC)
Website
CRC Industries, Inc. 885 Louis Dr. Warminster, PA 18974 US
215-674-4300 800-521-3168
800-272-4620 800-424-9300 (US) 703-527-3887 (International) www.crcindustries.com
2. Hazard(s) identification
Physical hazards Health hazards
Environmental hazards OSHA defined hazards
Flammable aerosols
Gases under pressure Serious eye damage/eye irritation
Reproductive toxicity (the unborn child) Specific target organ toxicity, single exposure Specific target organ toxicity, repeated exposure Hazardous to the aquatic environment, acute hazard Not classified.
Category 1 Compressed gas Category 2 Category 2 Category 3 narcotic effects Category 2
Category 3
Label elements
Signal word Hazard statement
Precautionary statement Prevention
Danger
Extremely flammable aerosol. Contains gas under pressure; may explode if heated. Causes serious eye irritation. May cause drowsiness or dizziness. Suspected of damaging the unborn child. May cause damage to organs (liver, kidneys, brain, lungs) through prolonged or repeated exposure. Harmful to aquatic life.
Obtain special instructions before use. Do not handle until all safety precautions have been read and understood. Keep away from heat/sparks/open flames/hot surfaces. - No smoking. Do not spray on an open flame or other ignition source. Do not apply while equipment is energized. Pressurized container: Do not pierce or burn, even after use. Extinguish all flames, pilot lights and heaters. Vapors will accumulate readily and may ignite. Use only with adequate ventilation; maintain ventilation during use and until all vapors are gone. Open doors and windows or use other means to ensure a fresh air supply during use and while product is drying. If you experience any symptoms listed on this label, increase ventilation or leave the area. Do not breathe mist or vapor. Wash thoroughly after handling. Wear protective gloves/protective clothing/eye protection/face protection. Avoid release to the environment.
Material name: Brakleen Brake Parts Cleaner 05151 Version #: 01 Issue date: 05-26-2015
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SDS US
1 / 10
Response
If inhaled: Remove person to fresh air and keep comfortable for breathing. Call a poison center/doctor if you feel unwell. If in eyes: Rinse cautiously with water for several minutes. Remove contact lenses, if present and easy to do. Continue rinsing. If eye irritation persists: Get medical attention. If exposed or concerned: Get medical attention.
Storage
Store in a well-ventilated place. Store locked up. Protect from sunlight. Do not expose to temperatures exceeding 50C/122F. Exposure to high temperature may cause can to burst.
Disposal
Dispose of contents/container in accordance with local/regional/national regulations.
Hazard(s) not otherwise classified (HNOC)
Static accumulating flammable liquid can become electrostatically charged even in bonded and grounded equipment. Sparks may ignite liquid and vapor. May cause flash fire or explosion.
Supplemental information 11.8% of the mixture consists of component(s) of unknown acute hazards to the aquatic environment.
3. Composition/information on ingredients
Mixtures
Chemical name
Common name and synonyms
Acetone
Carbon dioxide
Toluene
CAS number 67-64-1 124-38-9 108-88-3
Specific chemical identity and/or percentage of composition has been withheld as a trade secret.
% 80 - 90 10 - 20
1 - 3
4. First-aid measures
Inhalation
Skin contact Eye contact
Ingestion Most important symptoms/effects, acute and delayed Indication of immediate medical attention and special treatment needed General information
Remove victim to fresh air and keep at rest in a position comfortable for breathing. Call a POISON CENTER or doctor/physician if you feel unwell. Rinse skin with water/shower. Get medical attention if irritation develops and persists.
Immediately flush eyes with plenty of water for at least 15 minutes. Remove contact lenses, if present and easy to do. Continue rinsing. Get medical attention if irritation develops and persists. In the unlikely event of swallowing contact a physician or poison control center. Rinse mouth.
May cause drowsiness and dizziness. Headache. Nausea, vomiting. Severe eye irritation. Symptoms may include stinging, tearing, redness, swelling, and blurred vision. Prolonged exposure may cause chronic effects.
Provide general supportive measures and treat symptomatically. Keep victim under observation. Symptoms may be delayed.
IF exposed or concerned: Get medical advice/attention. Ensure that medical personnel are aware of the material(s) involved, and take precautions to protect themselves. Show this safety data sheet to the doctor in attendance.
5. Fire-fighting measures
Suitable extinguishing media
Unsuitable extinguishing media Specific hazards arising from the chemical
Special protective equipment and precautions for firefighters Fire-fighting equipment/instructions General fire hazards
Alcohol resistant foam. Water fog. Carbon dioxide (CO2). Dry chemical powder, carbon dioxide, sand or earth may be used for small fires only.
Do not use water jet as an extinguisher, as this will spread the fire.
Contents under pressure. Pressurized container may rupture when exposed to heat or flame. This product is a poor conductor of electricity and can become electrostatically charged. If sufficient charge is accumulated, ignition of flammable mixtures can occur. Static electricity accumulation may be significantly increased by the presence of small quantities of water or other contaminants. Material will float and may ignite on surface of water. During fire, gases hazardous to health may be formed.
Firefighters must use standard protective equipment including flame retardant coat, helmet with face shield, gloves, rubber boots, and in enclosed spaces, SCBA.
In case of fire: Stop leak if safe to do so. Move containers from fire area if you can do so without risk. Containers should be cooled with water to prevent vapor pressure build up.
Extremely flammable aerosol. Contents under pressure. Pressurized container may rupture when exposed to heat or flame.
Material name: Brakleen Brake Parts Cleaner 05151 Version #: 01 Issue date: 05-26-2015
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SDS US
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6. Accidental release measures
Personal precautions, protective equipment and emergency procedures
Keep unnecessary personnel away. Keep people away from and upwind of spill/leak. Keep out of low areas. Remove all possible sources of ignition in the surrounding area. Many vapors are heavier than air and will spread along ground and collect in low or confined areas (sewers, basements, tanks). Wear appropriate protective equipment and clothing during clean-up. Do not breathe mist or vapor. Emergency personnel need self-contained breathing equipment. Do not touch damaged containers or spilled material unless wearing appropriate protective clothing. Ventilate closed spaces before entering them. Use appropriate containment to avoid environmental contamination. Local authorities should be advised if significant spillages cannot be contained. For personal protection, see section 8 of the SDS.
Methods and materials for containment and cleaning up
Eliminate all ignition sources (no smoking, flares, sparks, or flames in immediate area). Keep combustibles (wood, paper, oil, etc.) away from spilled material. Stop the flow of material, if this is without risk. Prevent product from entering drains. Wipe up with absorbent material (e.g. cloth, fleece). Clean surface thoroughly to remove residual contamination. For waste disposal, see section 13 of the SDS.
Environmental precautions
Avoid release to the environment. Prevent further leakage or spillage if safe to do so. Avoid discharge into drains, water courses or onto the ground. Inform appropriate managerial or supervisory personnel of all environmental releases. Use appropriate containment to avoid environmental contamination.
7. Handling and storage
Precautions for safe handling
Conditions for safe storage, including any incompatibilities
Obtain special instructions before use. Do not handle until all safety precautions have been read and understood. Minimize fire risks from flammable and combustible materials (including combustible dust and static accumulating liquids) or dangerous reactions with incompatible materials. Pressurized container: Do not pierce or burn, even after use. Do not use if spray button is missing or defective. Do not spray on a naked flame or any other incandescent material. Do not smoke while using or until sprayed surface is thoroughly dry. Do not cut, weld, solder, drill, grind, or expose containers to heat, flame, sparks, or other sources of ignition. Use caution around energized equipment. The metal container will conduct electricity if it contacts a live source. This may result in injury to the user from electrical shock and/or flash fire. Do not breathe mist or vapor. Avoid contact with eyes. Avoid prolonged exposure. Pregnant or breastfeeding women must not handle this product. Should be handled in closed systems, if possible. Use only in well-ventilated areas. Wear appropriate personal protective equipment. Observe good industrial hygiene practices. Avoid release to the environment. For product usage instructions, please see the product label.
Level 3 Aerosol.
Pressurized container. Protect from sunlight and do not expose to temperatures exceeding 50C/122 F. Do not puncture, incinerate or crush. Do not handle or store near an open flame, heat or other sources of ignition. This material can accumulate static charge which may cause spark and become an ignition source. Avoid spark promoters. These alone may be insufficient to remove static electricity. Store in a well-ventilated place. Store away from incompatible materials (see Section 10 of the SDS).
8. Exposure controls/personal protection
Occupational exposure limits
US. OSHA Table Z-1 Limits for Air Contaminants (29 CFR 1910.1000)
Components
Type
Acetone (CAS 67-64-1)
PEL
Carbon dioxide (CAS
PEL
124-38-9)
US. OSHA Table Z-2 (29 CFR 1910.1000) Components Toluene (CAS 108-88-3)
US. ACGIH Threshold Limit Values Components Acetone (CAS 67-64-1)
Type Ceiling TWA
Type STEL TWA
Value 2400 mg/m3 1000 ppm 9000 mg/m3
5000 ppm
Value 300 ppm 200 ppm
Value 750 ppm 500 ppm
Material name: Brakleen Brake Parts Cleaner 05151 Version #: 01 Issue date: 05-26-2015
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SDS US
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US. ACGIH Threshold Limit Values Components
Type
Value
Carbon dioxide (CAS 124-38-9)
Toluene (CAS 108-88-3)
STEL
TWA TWA
US. NIOSH: Pocket Guide to Chemical Hazards
Components
Type
30000 ppm 5000 ppm 20 ppm
Value
Acetone (CAS 67-64-1) Carbon dioxide (CAS 124-38-9)
Toluene (CAS 108-88-3)
Biological limit values
ACGIH Biological Exposure Indices
Components
Value
TWA STEL
TWA STEL TWA
590 mg/m3 250 ppm 54000 mg/m3
30000 ppm 9000 mg/m3 5000 ppm 560 mg/m3 150 ppm 375 mg/m3 100 ppm
Determinant
Specimen Sampling Time
Acetone (CAS 67-64-1) Toluene (CAS 108-88-3)
50 mg/l 0.3 mg/g
0.03 mg/l 0.02 mg/l
Acetone
Urine
*
o-Cresol, with
Creatinine in
*
hydrolysis
urine
Toluene
Urine
*
Toluene
Blood
*
* - For sampling details, please see the source document.
Exposure guidelines
US - California OELs: Skin designation
Toluene (CAS 108-88-3) US - Minnesota Haz Subs: Skin designation applies
Can be absorbed through the skin.
Toluene (CAS 108-88-3)
Skin designation applies.
Appropriate engineering controls
Good general ventilation (typically 10 air changes per hour) should be used. Ventilation rates should be matched to conditions. If applicable, use process enclosures, local exhaust ventilation, or other engineering controls to maintain airborne levels below recommended exposure limits. If exposure limits have not been established, maintain airborne levels to an acceptable level. Provide eyewash station.
Individual protection measures, such as personal protective equipment
Eye/face protection
Wear safety glasses with side shields (or goggles).
Skin protection Hand protection Other
Respiratory protection
Thermal hazards General hygiene considerations
Wear protective gloves such as: Nitrile. Neoprene. Polyvinyl alcohol (PVA).
Wear suitable protective clothing.
If engineering controls are not feasible or if exposure exceeds the applicable exposure limits, use a NIOSH-approved cartridge respirator with an organic vapor cartridge. Use a self-contained breathing apparatus in confined spaces and for emergencies. Air monitoring is needed to determine actual employee exposure levels. Wear appropriate thermal protective clothing, when necessary.
When using do not smoke. Always observe good personal hygiene measures, such as washing after handling the material and before eating, drinking, and/or smoking. Routinely wash work clothing and protective equipment to remove contaminants.
9. Physical and chemical properties
Appearance
Physical state
Liquid.
Form
Aerosol.
Color
Clear. Colorless.
Material name: Brakleen Brake Parts Cleaner
05151 Version #: 01 Issue date: 05-26-2015
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Odor
Sweet.
Odor threshold
Not available.
pH
Not available.
Melting point/freezing point
-138.8 F (-94.9 C) estimated
Initial boiling point and boiling range
132.9 F (56.1 C) estimated
Flash point
< 0 F (< -17.8 C) Tag Closed Cup
Evaporation rate
Fast.
Flammability (solid, gas)
Not available.
Upper/lower flammability or explosive limits
Flammability limit - lower (%)
1.2 % estimated
Flammability limit - upper (%)
12.8 % estimated
Vapor pressure
6962 hPa estimated
Vapor density
2 (air = 1)
Relative density
0.88 estimated
Solubility (water)
Slightly soluble.
Partition coefficient (n-octanol/water)
Not available.
Auto-ignition temperature
869 F (465 C) estimated
Decomposition temperature
Not available.
Viscosity (kinematic)
Not available.
Percent volatile
88.2 % estimated
10. Stability and reactivity
Reactivity
The product is stable and non-reactive under normal conditions of use, storage and transport.
Chemical stability
Material is stable under normal conditions.
Possibility of hazardous reactions
No dangerous reaction known under conditions of normal use.
Conditions to avoid
Heat, flames and sparks. Avoid temperatures exceeding the flash point. Contact with incompatible materials.
Incompatible materials
Acids. Aluminum.
Hazardous decomposition products
Carbon oxides.
11. Toxicological information
Information on likely routes of exposure
Inhalation
May cause damage to organs through prolonged or repeated exposure by inhalation. May cause drowsiness and dizziness. Headache. Nausea, vomiting.
Skin contact
Prolonged skin contact may cause temporary irritation.
Eye contact
Causes serious eye irritation.
Ingestion
Acetone poisoning may result in liver and kidney damage.
Symptoms related to the physical, chemical and toxicological characteristics
Headache. May cause drowsiness and dizziness. Nausea, vomiting. Severe eye irritation. Symptoms may include stinging, tearing, redness, swelling, and blurred vision.
Information on toxicological effects
Acute toxicity
Narcotic effects.
Product
Species
Test Results
Brakleen Brake Parts Cleaner
Acute
Dermal LD50
Rabbit
22231 mg/kg estimated
Material name: Brakleen Brake Parts Cleaner 05151 Version #: 01 Issue date: 05-26-2015
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Product Inhalation LC50
Oral LD50
Species Rat
Rat
Test Results 33087 ppm, 4 hours estimated 82 mg/l, 4 Hours estimated
6560 mg/kg estimated
* Estimates for product may be based on additional component data not shown.
Skin corrosion/irritation
Prolonged skin contact may cause temporary irritation.
Serious eye damage/eye irritation
Causes serious eye irritation.
Respiratory sensitization
Not a respiratory sensitizer.
Skin sensitization
This product is not expected to cause skin sensitization.
Germ cell mutagenicity
No data available to indicate product or any components present at greater than 0.1% are mutagenic or genotoxic.
Carcinogenicity
This product is not considered to be a carcinogen by IARC, ACGIH, NTP, or OSHA.
IARC Monographs. Overall Evaluation of Carcinogenicity
Toluene (CAS 108-88-3)
3 Not classifiable as to carcinogenicity to humans.
Reproductive toxicity
Suspected of damaging the unborn child.
Specific target organ toxicity single exposure
May cause drowsiness and dizziness.
Specific target organ toxicity repeated exposure
May cause damage to organs through prolonged or repeated exposure: Liver. Kidneys. Brain. Lungs.
Aspiration hazard
Based on available data, the classification criteria are not met.
Chronic effects
May cause damage to organs through prolonged or repeated exposure. Prolonged inhalation may be harmful.
12. Ecological information
Ecotoxicity
Harmful to aquatic life.
Product
Species
Brakleen Brake Parts Cleaner
Aquatic
Acute
Fish
LC50
Fish
Components
Species
Acetone (CAS 67-64-1)
Aquatic Crustacea
EC50
Water flea (Daphnia magna)
Fish
LC50
Rainbow trout,donaldson trout
(Oncorhynchus mykiss)
Toluene (CAS 108-88-3)
Aquatic Crustacea
EC50
Water flea (Daphnia magna)
Fish
LC50
Coho salmon,silver salmon
(Oncorhynchus kisutch)
Test Results
7948.4028 mg/l, 96 hours estimated Test Results
10294 - 17704 mg/l, 48 hours 4740 - 6330 mg/l, 96 hours
5.46 - 9.83 mg/l, 48 hours 8.11 mg/l, 96 hours
* Estimates for product may be based on additional component data not shown. Persistence and degradability No data is available on the degradability of this product.
Bioaccumulative potential
Partition coefficient n-octanol / water (log Kow) Acetone Toluene
Mobility in soil
No data available.
-0.24 2.73
Material name: Brakleen Brake Parts Cleaner 05151 Version #: 01 Issue date: 05-26-2015
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Other adverse effects
No other adverse environmental effects (e.g. ozone depletion, photochemical ozone creation potential, endocrine disruption, global warming potential) are expected from this component.
13. Disposal considerations
Disposal of waste from residues / unused products
If discarded, this product is considered a RCRA ignitable waste, D001. Collect and reclaim or dispose in sealed containers at licensed waste disposal site. Contents under pressure. Do not puncture, incinerate or crush. Do not allow this material to drain into sewers/water supplies. Do not contaminate ponds, waterways or ditches with chemical or used container. Dispose in accordance with all applicable regulations.
Hazardous waste code
D001: Waste Flammable material with a flash point <140 F
Contaminated packaging
Since emptied containers may retain product residue, follow label warnings even after container is emptied. Empty containers should be taken to an approved waste handling site for recycling or disposal.
14. Transport information
DOT
UN number UN proper shipping name Transport hazard class(es)
Class Subsidiary risk Label(s) Packing group Special precautions for user Special provisions Packaging exceptions Packaging non bulk Packaging bulk IATA
UN number UN proper shipping name Transport hazard class(es)
Class Subsidiary risk Packing group Environmental hazards ERG Code Special precautions for user Other information
Passenger and cargo aircraft Cargo aircraft only IMDG
UN number UN proper shipping name Transport hazard class(es)
Class Subsidiary risk Packing group Environmental hazards
Marine pollutant EmS Special precautions for user
UN1950 Aerosols, flammable, Limited Quantity
2.1 2.1 Not applicable. Read safety instructions, SDS and emergency procedures before handling. N82 306 None None
UN1950 Aerosols, flammable, Limited Quantity
2.1 Not applicable. No. 10L Read safety instructions, SDS and emergency procedures before handling.
Allowed.
Allowed.
UN1950 AEROSOLS, LIMITED QUANTITY
2 Not applicable.
No. F-D, S-U Read safety instructions, SDS and emergency procedures before handling.
15. Regulatory information
US federal regulations
This product is a "Hazardous Chemical" as defined by the OSHA Hazard Communication Standard, 29 CFR 1910.1200.
TSCA Section 12(b) Export Notification (40 CFR 707, Subpt. D)
Not regulated. US. OSHA Specifically Regulated Substances (29 CFR 1910.1001-1050)
Not listed.
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SDS US
7 / 10
SARA 304 Emergency release notification
Not regulated. US EPCRA (SARA Title III) Section 313 - Toxic Chemical: Listed substance
Toluene (CAS 108-88-3) CERCLA Hazardous Substance List (40 CFR 302.4)
Acetone (CAS 67-64-1) Toluene (CAS 108-88-3) CERCLA Hazardous Substances: Reportable quantity
Listed. Listed.
Acetone (CAS 67-64-1) Toluene (CAS 108-88-3)
5000 LBS 1000 LBS
Spills or releases resulting in the loss of any ingredient at or above its RQ require immediate notification to the National Response Center (800-424-8802) and to your Local Emergency Planning Committee.
Clean Air Act (CAA) Section 112 Hazardous Air Pollutants (HAPs) List
Toluene (CAS 108-88-3) Clean Air Act (CAA) Section 112(r) Accidental Release Prevention (40 CFR 68.130)
Not regulated.
Safe Drinking Water Act (SDWA)
Not regulated.
Drug Enforcement Administration (DEA). List 2, Essential Chemicals (21 CFR 1310.02(b) and 1310.04(f)(2) and Chemical Code Number
Acetone (CAS 67-64-1)
6532
Toluene (CAS 108-88-3)
6594
Drug Enforcement Administration (DEA). List 1 & 2 Exempt Chemical Mixtures (21 CFR 1310.12(c))
Acetone (CAS 67-64-1) Toluene (CAS 108-88-3) DEA Exempt Chemical Mixtures Code Number
35 %WV 35 %WV
Acetone (CAS 67-64-1) Toluene (CAS 108-88-3)
6532 594
Food and Drug Administration (FDA)
Not regulated.
Superfund Amendments and Reauthorization Act of 1986 (SARA)
Section 311/312 Hazard categories
Immediate Hazard - Yes Delayed Hazard - Yes Fire Hazard - Yes Pressure Hazard - Yes Reactivity Hazard - No
SARA 302 Extremely No hazardous substance
US state regulations
US. California. Candidate Chemicals List. Safer Consumer Products Regulations (Cal. Code Regs, tit. 22, 69502.3, subd. (a))
Acetone (CAS 67-64-1) Toluene (CAS 108-88-3) US. California Controlled Substances. CA Department of Justice (California Health and Safety Code Section 11100)
Not listed. US. New Jersey Worker and Community Right-to-Know Act
Acetone (CAS 67-64-1) Carbon dioxide (CAS 124-38-9) Toluene (CAS 108-88-3) US. Massachusetts RTK - Substance List
Acetone (CAS 67-64-1) Carbon dioxide (CAS 124-38-9) Toluene (CAS 108-88-3) US. Pennsylvania Worker and Community Right-to-Know Law
Acetone (CAS 67-64-1) Toluene (CAS 108-88-3) Carbon dioxide (CAS 124-38-9) US. Rhode Island RTK
Acetone (CAS 67-64-1)
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8 / 10
Toluene (CAS 108-88-3)
US. California Proposition 65
WARNING: This product contains a chemical known to the State of California to cause cancer and birth defects or other reproductive harm.
US - California Proposition 65 - CRT: Listed date/Carcinogenic substance
Benzene (CAS 71-43-2)
Listed: February 27, 1987
Cumene (CAS 98-82-8)
Listed: April 6, 2010
Ethanal (CAS 75-07-0)
Listed: April 1, 1988
Ethylbenzene (CAS 100-41-4)
Listed: June 11, 2004
US - California Proposition 65 - CRT: Listed date/Developmental toxin
Benzene (CAS 71-43-2)
Listed: December 26, 1997
Toluene (CAS 108-88-3)
Listed: January 1, 1991
US - California Proposition 65 - CRT: Listed date/Female reproductive toxin
Toluene (CAS 108-88-3)
Listed: August 7, 2009
US - California Proposition 65 - CRT: Listed date/Male reproductive toxin
Benzene (CAS 71-43-2)
Listed: December 26, 1997
Volatile organic compounds (VOC) regulations
EPA
VOC content (40 CFR 51.100(s))
2.7 %
Consumer products (40 CFR 59, Subpt. C)
Not regulated
State Consumer products
This product is regulated as a Brake Cleaner. This product is compliant for use in all 50 states. This product also complies with South Coast Air Quality Management District Rule 1171.
VOC content (CA)
2.7 %
VOC content (OTC)
2.7 %
International Inventories
Country(s) or region Australia
Inventory name Australian Inventory of Chemical Substances (AICS)
On inventory (yes/no)* Yes
Canada
Domestic Substances List (DSL)
Yes
Canada
Non-Domestic Substances List (NDSL)
No
China
Inventory of Existing Chemical Substances in China (IECSC)
Yes
Europe
European Inventory of Existing Commercial Chemical
Yes
Substances (EINECS)
Europe
European List of Notified Chemical Substances (ELINCS)
No
Japan
Inventory of Existing and New Chemical Substances (ENCS)
Yes
Korea
Existing Chemicals List (ECL)
Yes
New Zealand
New Zealand Inventory
Yes
Philippines
Philippine Inventory of Chemicals and Chemical Substances
Yes
(PICCS)
United States & Puerto Rico Toxic Substances Control Act (TSCA) Inventory
Yes
*A "Yes" indicates that all components of this product comply with the inventory requirements administered by the governing country(s) A "No" indicates that one or more components of the product are not listed or exempt from listing on the inventory administered by the governing country(s).
16. Other information, including date of preparation or last revision
Issue date
05-26-2015
Prepared by
Allison Cho
Version #
01
Further information
CRC # 668A
HMIS ratings
Health: 1* Flammability: 4 Physical hazard: 0 Personal protection: B
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SDS US
9 / 10
NFPA ratings NFPA ratings
Disclaimer
Health: 1 Flammability: 4 Instability: 0
4 10
The information contained in this document applies to this specific material as supplied. It may not be valid for this material if it is used in combination with any other materials. This information is accurate to the best of CRC Industries' knowledge or obtained from sources believed by CRC to be accurate. Before using any product, read all warnings and directions on the label. For further clarification of any information contained on this (M)SDS consult your supervisor, a health & safety professional, or CRC Industries.
Material name: Brakleen Brake Parts Cleaner 05151 Version #: 01 Issue date: 05-26-2015
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SDS US
10 / 10
APPENDIX 3. PHOTOGRAPH OF LABELED USED OIL
Properly labeled drum of Used Oil
Appendix 3 Page 1 of 1