# Product Stewardship Manual Safe Handling and Storage

DOW TM Epichlorohydrin2 Introduction Pages 3-4 Product Stewardship 3 Responsible Care ® 3 Customer Notice 4
Emergency Contact Information Pages 5
Properties and Uses Pages 6-11 Physical Properties 6 Chemical Reactivity 6 Product Uses 10
Health, Safety, and Handling Pages 12-20 Health Hazards 12 Decontamination, First Aid, and Physician Notes 14 Personal Protective Equipment 17 Sampling of Delivery Vehicles 19
Emergency Preparedness Pages 21-25 Plan Development 21 Transportation Emergency 22 Fire-Fighting Guidelines 23 Spill Clean-Up 24 Waste Disposal 25
Delivery Procedures Pages 26-30 Road Shipments 27 Rail Shipments 27 Delivery Checklist 29
Storage and Equipment Pages 31-39 Materials of Construction 31 Bulk Handling Checklist 32 Tank Storage 36 Tank Cleaning Procedures 37 Equipment Specifications 39
Analytical Methods Pages 40
Regulatory Requirements Pages 41-42 Chemical Inventory Listing 41 International Transportation Requirements 42 Appendix Pages 43-46 

# Table of Contents

DOW TM Epichlorohydrin

® Responsible Care is a service mark of the American Chemistry Council in the United States TM Trademark of The Dow Chemical Company (“Dow”) or an affiliated company of Dow3 

# Epichlorohydrin is a highly reactive chemical intermediate available since 1957 from The Dow Chemical Company (Dow). Today, Dow is one of the largest producers of epichlorohydrin in the world, with a capacity of more than 450,000 metric tons/year (more than 1 billion pounds/year) from plants in Freeport, Texas, U.S.A., and Stade, Germany. In its pure form, epichlorohydrin is a clear, colorless liquid. The presence of both an epoxide ring and a chlorine atom in the molecule allows epichlorohydrin to readily undergo a variety of chemical reactions with many types of compounds. This versatility earns its wide use as a chemical intermediate. Regardless of its uses, epichlorohydrin must be handled carefully to protect the health of employees, customers, the public, and the environment. Although your company is responsible for its own safety procedures, our goal is to make that task easier with this manual. Read it prior to handling or using epichlorohydrin products, and use it as a training tool for new employees. For additional assistance, you can ask Dow to: • Support your engineering and

industrial hygiene monitoring
programs; • Make a pre-delivery evaluation of

your site and provide suggestions for improvement; • Conduct on-site training for your

employees; • Attend the first delivery to assist in

a safe and spill-free product transfer. We want to put our experience with epichlorohydrin to work for you. 

## Product Stewardship Dow and its employees have a fundamental concern for all who make, distribute, and use its products, and for the environment in which we live. This concern is the basis for our Product Stewardship philosophy by which we assess the health and environmental information on our products and take appropriate steps to protect employee and public health and our environment. Our Product Stewardship program rests with each and every individual involved with Dow products, from initial concept and research, to the manufacture, sale, distribution, use, and recycling or disposal of each product. 

## Responsible Care ® Dow has a long-standing policy to ensure that its operations do not have an adverse impact on the community or the environment. To uphold this policy, Dow is committed to Responsible Care ® , a continuing effort by the chemical industry to improve the responsible management of chemicals. Under Responsible Care, Dow complies with 10 Guiding Principles and Codes of Management Practices that cover all aspects of research, development, manufacture, distribution, transportation, use, and disposal of products. These principles also extend to prompt reporting, customer counseling, community awareness, support of external research, participation with government and others, and promotion of Responsible Care worldwide. 

# Introduction

DOW TM Epichlorohydrin

®Responsible Care is a service mark of the American Chemistry Council in the United States TM Trademark of The Dow Chemical Company (“Dow”) or an affiliated company of Dow4 Dow recognizes that no single entity can protect the quality of all of our air and water. However, by working together on a global basis, the public, industry, and government can make the future brighter and safer. There are joint European Chemical Industry Council(CEFIC)/the European Association of Chemical Distributors (FECC) Responsible Care guidelines available via CEFIC’s web page, www.cefic.org, and on www.responsiblecare.org.


## Customer Notice Dow encourages its customers and potential users of Dow products to review their applications for such products from the standpoint of human health and environmental quality. To help ensure that Dow products are not used in ways for which they were not intended or tested, Dow personnel are available to assist customers in dealing with ecological and product safety considerations. Your Dow sales representative can arrange for the proper contacts. Dow literature, including Material Safety Data Sheets (MSDSs) or Safety Data Sheets (SDSs), should be consulted prior to the use of Dow products. Or visit our Product Safety web site, www.dow.com/productsafety. Dow believes the information and suggestions contained in this manual to be accurate and reliable as of January 2007. However, since any assistance furnished by Dow with reference to the proper use and disposal of its products is provided without charge, and since use conditions and disposal are not within its control, Dow assumes no obligation or liability for such assistance and does not guarantee results from use of such products or other information herein. No warranty, express or implied, is given nor is freedom from any patent owned by Dow or others to be inferred. Information herein concerning laws and regulations is based on U.S. federal laws and regulations except where specific reference is made to those of other jurisdictions. Since use conditions and government requirements may differ from one location to another and may change with time, it is the customer’s responsibility to determine whether Dow’s products are appropriate for the customer’s use, and to assure that the customer’s workplace and disposal practices comply with applicable government requirements. Introduction5 

# T his Product Stewardship manual contains important information about DOWTM Epichlorohydrin that will help you and your employees to safely handle, store, and dispose of this material. If other raw materials are used in your system, be sure to request suggestions for handling, storage, and disposal from the appropriate suppliers prior to working with those materials. For more information about DOW Epichlorohydrin, refer to the MSDS/SDS or contact your Dow representative. See the Appendix for country-specific contacts and telephone numbers. For emergencies, call the Dow Emergency Response Centers (24-hour Help Desk): 

# Emergency Contact Information

Table 1: Global Emergency Contact List Area Country Emergency Contact North America & All +1 (979) 238-2112 (Dow Freeport, U.S.A.) Latin America Europe All +31 115 69 4982 (Dow Terneuzen, The Netherlands) India, Middle East & All +31 115 69 4982 (Dow Terneuzen, Africa The Netherlands)
Asia Pacific All +852 2431 3300 Non-Dow Emergency Organizations
North America U.S.A. CHEMTREC +1 800 424-9300 Canada CANUTEC +1 (613) 996-6666 Central America Mexico SETIQ Republic +91 800 00 214 Europe All ICE (European Emergency Response Network with national emergency centers) (1)

DOW TM Epichlorohydrin

TM Trademark of The Dow Chemical Company (“Dow”) or an affiliated company of Dow (1) Call the Dow Emergency Reponse Centers for help in identifying local assistance through

the European Emergency Reponse Network.6 

## Physical Properties

The chemical structure of epichlorohydrin is shown in Figure 1. Physical properties are provided in Table 2 and in Figures 2 and 3. Typical chemical reactions are provided in Table 3. 

## Chemical Reactivity At high temperatures, epichlorohydrin can react violently and in some cases explosively (spontaneous polymerization) in the presence of certain substances. These substances may include:
• Acids • Alcohols • Alkalis • Aluminum, magnesium, copper,

tin, zinc, and other alloys
• Amines
• Ammonia • Carbon monoxide • Metal halides (such as iron

III-chloride) • Metal hydroxides • Metal oxides • Salts 

# Properties and Uses

Figure 1: Chemical Structure of Epichlorohydrin

Table 2: Physical Properties of Epichlorohydrin (1) Property Description Appearance Colorless liquid Auto-ignition Temperature 416 ̊C (781 ̊F) Boiling Point (1.013 kPa, 1 atm) 116.4 ̊C (241.6 ̊F)
CAS Number 106-89-8 ID Number (Annex I*) 603-026-00-6 EC Number (EINECS) 203-439-8 Chemical Name 1-chloro-2,3-epoxypropane Common Name Epichlorohydrin (ECH or EPI) Decomposition Temperature 217 ̊C (423 ̊F) Density lb/gal, at 25 ̊C 9.8 g/l 1,174.5 lb/ft 3 73.3 Dielectric Constant, at 20 ̊C 23 Empirical Formula C 3H 5OCl
Flammable Limits, Volume in Air Lower Limit (%) 3.8 Upper Limit (%) 21 Flammable Limits, Volume Oxygen in Epichlorohydrin Lower Limit (%) 11.6 Evaporation Rate 1.35 (butyl acetate = 1) Flash Point, TCC (Tag Closed Cup) 31 ̊C (87.8 ̊F) Heat Capacity J/mol, at 25 ̊C 131.9 (31.5 cal/mol) J/mol, at 100 ̊C 166.2 (39.7 cal/mol)
Heat of Formation kJ/mol, at 25 ̊C -149.0 (-35.6 kcal/mol) BTU/lb, at 77 ̊F -693.1

Heat of Fusion kJ/mol, at 25 ̊C 10.5 (2,500 cal/mol) Btu/lb, at 77 ̊F 49 (Table continued) 

## H 2 

## C––CH––CH 2 

## CI O

DOWTM Epichlorohydrin Note: A mixture of epichlorohydrin and water, in which a two-phase mixture forms, will create a particular hazard (see Table 2, solubility information). Over time, an exothermic reaction will start at the interface which can generate enough heat to create a pressure build-up in the tank. Such mixtures must be disposed of promptly (see page 21, “Emergency Preparedness,” for disposal information).

*Annex I to EU directive 67/548/EC as amended TM Trademark of The Dow Chemical Company (“Dow”) or an affiliated company of Dow7 

### Table 2: Physical Properties of Epichlorohydrin (1)

### (continued) Property Description Heat of Homopolymerization kJ/mol, at 25  ̊ C 101.7 (24.3 kcal/mol) Heat of Vaporization kJ/mol, at 25  ̊ C 42.4 (10.1 kcal/mol) Btu/lb, at 77  ̊ F 196.9 Oxygen Content Required for 11.6 Combustion, vol% (2) Melting Point -57.1  ̊ C (-71.9  ̊ F) Molecular Weight (g/mol) 92.53 Odor Sweet, pungent
Odor Threshold (3) Mean odor recognition (ppm) 10 Odor recognized by majority 25 of individuals (ppm)
Refractive Index n D 20 1.435
Saturated Concentration 1.7 (% volume in air at 20  ̊ C (68  ̊ F) Solubility, at 25  ̊ C Acetone Infinite Benzene Infinite Carbon Tetrachloride Infinite Diethylether Infinite n-Heptane Infinite Methanol Infinite In Water, at 20  ̊ C (%) 6.6 Water In, at 20  ̊ C (%) 1.5 Specific Gravity, at 25/25  ̊ C 1.178 Specific Heat Ratio, at 25  ̊ C 1.1131
Surface Tension N/cm, at 25  ̊ C 36.4 x10 -5 N/cm, at 100  ̊ C 26.3 x10 -5 Vapor Density, relative (air = 1) 3.27 Vapor Pressure (kPa) 0  ̊ C 0.46 (3.5 mmHg) 25  ̊ C 2.28 (17.1 mmHg) 50  ̊ C 8.36 (62.7 mmHg) 100  ̊ C 60.35 (452.7 mmHg) Viscosity (mPa • s at 25  ̊ C) 1.086 (1.086 cP)

(1) Typical properties, not to be construed as specifications.

(2) A maximum concentration of 8% oxygen is required for storage tanks, vessels and

transportation equipment to ensure that the vapor never forms a flammable mixture.

(3) Odor threshold variously reported from less than 1 ppm to 25 ppm (See “Odor

Threshold and Warning Properties,” on page 12). Properties and Uses8 

### Figure 2: Vapor Pressure of Epichlorohydrin (1) Properties and Uses



### Figure 3: Density of Epichlorohydrin (1) (1) These are typical values only, and are not to be regarded as sales specifications; users are

advised to confirm for their operations.

(1) These are typical values only, and are not to be regarded as sales specifications; users are

advised to confirm for their operations. (1) These are typical values only, and are not to be regarded as sales specifications; users are

advised to confirm for their operations.

(1) These are typical values only, and are not to be regarded as sales specifications; users are

advised to confirm for their operations.9 Properties and Uses

Alcohols CH 2––CH––CH 2 CI + ROH O
catalyst R––O––CH 2––CHOH––CH 2 CI

CH 2––CH––CH 2 CI + ROH + NaOH O

H 2 O R––O––CH 2––CH––CH 2 + NaCI + H 2 O O

Organic Acids and Salts CH 2––CH––CH 2 CI + RCOOH O

RCOO––CH 2––CHOH––CH 2 CI

HO––CH 2––CHOOCR––CH 2 CI

+

CH 2––CH––CH 2 CI + RCOONa O

ROOCH 2––CH––CH 2+ NaCI O

CH 2––CH––CH 2 CI + (RCO) 2 O O

RCOOCH 2––CH(OOCR)––CH 2 CI Anhydrides

CH 2––CH––CH 2 CI + RCOCI O

CH 2 CI––CH(OOCR)––CH 2 CI Acyl Chlorides
R H

O O C

CH 2––CH––CH 2 CI + RCHO CICH 2 ––CH––CH 2 Aldehydes O

R R 1

O O C

CH 2––CH––CH 2 CI + RCOR 1 CICH 2 ––CH––CH 2 Ketones O

CH 2––CH––CH 2 CI + RHNH RHNCH 2 ––CHOH––CH 2 CI Amines O

CH 2––CH––CH 2 CI + RMgBr CH 2 R––CHOMgBr––CH 2 CI Grignard Reagents O

CCH 2 R––CHOH––CH 2 CI CH 2 OMgBr––CHR––CH 2 CI H 2 O +

CH 2 OH––CHR––CH 2 CI +

CH 2––CH––CH 2 CI + HOH CH 2 OH––CHOH––CH 2 CI Water O

CH 2––CH––CH 2 CI CH 2 OH––CHOH––CH 2 OH + NaCI Water and Sodium Hydroxide O

CH 2––CH––CH 2 CI + HCI CH 2 CI––CHOH––CH 2 CI Inorganic Acids and Salts O

CH 2––CH––CH 2 CI + NaHSO 3 CH 2 CI––CHOH––CH 2 ––SO 3 Na O H 2 O

CH 2––CH––CH 2 CI + RSH RS––CH 2 ––CHOH––CH 2 CI Organic Sulfur O

CH 2––CH––CH 2 CI + RSH O

R––S––CH 2––CH––CH 2 + NaCI + H 2 O NaOH O 

### Table 3: Typical Reactions of Epichlorohydrin10 

## Product Uses Epichlorohydrin is an extremely versatile chemical intermediate that finds its use in a wide variety of applications - from epoxy resins and textiles, to ion exchange resins, rubbers, agricultural products, and

more. 

### Epoxy Resins Epichlorohydrin is primarily used to manufacture epoxy resins. Epoxy resins are generally produced by reacting a polyhydric phenol with an aliphatic chlorohydrin or simple aliphatic epoxide. The most familiar epoxy is obtained by condensing epichlorohydrin with bisphenol A, resulting in a basic epoxy resin molecule, such as that shown in Figure 4. Major advantages of epoxy resins include corrosion resistance, solvent and chemical resistance, hardness, and adhesion. 

### Figure 4: Basic Epoxy Resin Molecule

Other derivatives of epichlorohydrin may be obtained by: • Coupling this basic epoxy structure with materials containing an active

hydrogen, such as aldehydes, polyamides, and polyamines. • Crosslinking it with amine or acid curing agents. • Esterifying it with short- or long-chain unsaturated acids.



### Textiles In the textile industry, epichlorohydrin is used to modify the carboxyl groups of wool. The resulting product has a longer and improved resistance to moths. Epichlorohydrin also is used to prepare protein-modified, wool-like fibers which have an affinity for acid dyes and which exhibit resistance to both mold and insects. Further, epichlorohydrin is used to prepare dyeable polypropylene fibers and to dye polyolefin, polyacrylonitrile, polyvinyl chloride, polyvinyl alcohol, andother fibers. It is also used to impart wrinkle resistance and to prepare antistatic agents and textile sizings. Derivatives of epichlorohydrin show utility as leveling, dispersion, softening, emulsifying and washing agents.


### Papers, Inks, Dyes Wet-strength paper sizing is prepared from either polyamides modified with epichlorohydrin or from the reaction product of epichlorohydrin and an alkylene amine. Epichlorohydrin polyhydroxy compounds and their esters are useful in the production of special printing inks and textile print pastes. These products yield flexible films that are chemically inert to caustic soda and other chemical solutions. Epichlorohydrin adducts are useful as filler retention aids, paper coatings, flocculants, and anti-static agents. Paper and paperboard products with improved printability, pigment retention, folding endurance, and gloss also are prepared with epichlorohydrin reaction products. Properties and Uses

H––C–––––C––C

–––––O–– ––C

–– ––O ––C––C––C

––––– O–– ––C

–– ––O ––C––C––––––C––H H I H I H I H I H I H I CH 3 I CH 3 I H I H I H I
I H I H I O H I H I H I CH 3 I CH 3 n O O11 

### Ion Exchange Resins Epichlorohydrin is used to produce both anion- and cation-exchangeresins. Water-insoluble anionexchange resins having good stability are prepared by reacting epichlorohydrin with ethylenediamine or a higherhomolog. Strong-base anionexchange resins can be produced by reacting epichlorohydrin with polymeric tertiary amines. Epichlorohydrin-based anion exchangers are used successfully to purify drinking water and to clean polluted air. Cation-exchange resins are produced by condensing epichlorohydrin with polyhydroxy phenols and by sulfonating the product.


### Surface Active Agents Many epichlorohydrin-based, surface-active agents are synthesized by condensing the epichlorohydrin with a polyamine such as tetraethylene-pentamine, plus a fatty acid such as stearic acid. The polyamine and fatty acid may be replaced with an alkali metal, starch, or other reactant. Sulfonated epichlorohydrin is occasionally substituted for epichlorohydrin. Such products find use in cosmetics and shampoos, and as detergents, sudsing agents, water softeners, and demulsifiers. 

### Epichlorohydrin-Based Rubber Epichlorohydrin is polymerized or copolymerized with ethylene oxide to form elastomers. These elastomers, members of a family of specialty polyether rubbers, possess excellent physical properties over a wide range of temperatures and are resistant to fuel, oil, and ozone. Other advantages are excellent aging characteristics, high resiliency, and flexibility at low temperatures.Applications for epichlorohydrinbased rubber include automotive and aircraft parts, seals and gaskets, wire and cable jackets, adhesives,packings, hose and belting, rubbercoated fabrics, and energy absorbing units.



### Plasticizers The reaction of epichlorohydrin with alcohols, alcoholates, or the sodium salts of stearic, oleic, palmitic, myristic, and other fatty acids yields products used as vinyl polymer plasticizers, solvents for food and flavoring, and plasticizers for polyurethanes. Properties and Uses



### Agricultural Products Biologically active compounds are prepared by reacting epichlorohydrin with alcohols or the sodium salts of alkylphenols. Such products have found effective use in insecticides, bactericides, and fungicides.


### More Applications Other applications for derivatives of epichlorohydrin include: • Asphalt improvers • Corrosion inhibitors • Electrical insulation for wire • Fire-retardant urethanes • Hair conditioning rinses • Liners for polyethylene bottles • Linoleum and linoleum cements • Lubricant additives • Petroleum production aids • Pharmaceuticals • Photographic film bases • Rubber latex coagulation aids • Waterproofing compounds • Zinc electroplating compounds12 

# Health, Safety, and Handling


# T he information in this section is general and should be used in conjunction with the most current epichlorohydrin MSDS/SDS. A current MSDS/SDS can be obtained from your Dow representative or by calling the Dow Customer Information Group (CIG) at +1 800 441-4369 in the United States. MSDS/SDS can also be obtained from the Dow Internet home page, www.dow.com. The MSDS/SDS should be reviewed prior to working with epichlorohydrin.



## Health Hazards

Odor Threshold and Warning Properties Epichlorohydrin has a sweet, pungent smell with an odor threshold variously reported at values less than 1 part per million (ppm) to 25 ppm. Sensory perception studies have indicated that the mean threshold for odor recognition of epichlorohydrin is 10 ppm, and that at 25 ppm it is recognized by the majority of persons. These findings are supported by the epichlorohydrin subcommittee of the Society of the Plastics Industry (SPI), in its publication,

“ Epichlorohydrin, Safety and Handling Guide ,” September 1994. Marked nose and eye irritation occur only at levels that exceed 100 ppm. Note: Workers must not rely on odor, or on eye and nose irritability, as a warning or indicator of exposure potentials.
For more information, refer to:

• Odor as an Aid to Chemical Safety: Odor Thresholds Compared With

Threshold Limit Values and Volatilities for 214 Industrial Chemicals in Air and Water Dilution , J.E. Amoore and E. Hautala, Journal of Applied Toxicology, Vol. 3, No. 6, 1983.

• Odor Thresholds and Irritation Levels of Several Chemical Substances: A

Review , Jon H. Ruth, American Industrial Hygiene Association Journal (1958-1999)(1986), 47(3).

• Patty’s Industrial Hygiene and Toxicology, Fourth Edition, Vol. 2, Part A,

Chapter 7, 1993, Wiley & Sons, Inc. pp. 422.


### Acute Toxicity - Systemic Effects Excessive vapor concentrations are readily attainable at room temperature and may cause unconsciousness and death. At 25 ̊C (77 ̊F), epichlorohydrin has a vapor pressure of 2.26 kPa (17 mmHg). This is equivalent to 22,000 ppm by volume. The one-hour LC50 value is 3617 ppm for male rats and 2165 ppm for female rats.



### Inhalation Epichlorohydrin vapor is irritating to the mucous membranes of the respiratory tract. Lung injury, which may be delayed, can result from inhalation of epichlorohydrin vapor. Liver and kidney injury can result from respiratory exposure or prolonged skin contact. DOW TM Epichlorohydrin

TM Trademark of The Dow Chemical Company (“Dow”) or an affiliated company of Dow13 

### Ingestion While epichlorohydrin does display moderate acute oral toxicity (the oral LD50 has been reported in the range of 175-282 mg/kg, depending on the particular species tested), it is unlikely that acutely toxic amounts of epichlorohydrin would be ingested in the course of ordinary operations. However, should appreciable amounts be willfully or accidentally ingested, serious injury, including death, could result. Epichlorohydrin, therefore, should be kept in the original containers (appropriately labeled), which should be closed and kept away from persons inexperienced with proper handling and use.



### Contact Effects The following effects of epichlorohydrin on the skin and eyes should be carefully noted by all individuals working with this material.



### Skin Contact Epichlorohydrin is irritating and can be damaging to the skin, particularly if contact exceeds a few minutes. Exposure may not be apparent and irritation or damage may not develop for several hours. Prolonged contact will invariably cause serious chemical burns, even at low concentrations. Epichlorohydrin has caused allergic skin reactions in humans and is therefore classified as a skin sensitizer. Epichlorohydrin is also readily absorbed through intact skin in harmful amounts (the LD50 for skin absorption in rabbits is 515 mg/kg). Systemic intoxication from repeated skin contacts can be hazardous. 

### Eye Contact Eye contact with epichlorohydrin liquid will produce moderate irritation with corneal injury. Solutions of epichlorohydrin may cause more irritation and injury if the solvent carrying the epichlorohydrin is miscible with water. Epichlorohydrin vapor is also very irritating to the eyes.


### Chronic Toxicity - Systemic Effects Repeated inhalation of epichlorohydrin vapor has resulted in liver and kidney injury to laboratory animals. In animal studies, a reversible decrease in fertility was observed in male rats; however, a number of epidemiological studies which investigated epichlorohydrin exposure and health effects in workers have shown no association with reproduction effects.



### Burn Potential The chemical burn potential with epichlorohydrin is well-known and identified in the MSDS/SDS as a hazard. In an actual chemical burn incident, a worker wearing leather boots received a small splash on his impervious outer (slicker) suit during a truck off-loading operation. The worker washed the contamination from the suit shortly after the incident and again before storing the suit. He was unaware that a minor contamination of his boot had occurred. Approximately eight hours after the exposure, the worker noted itching on one of his feet. He noted three irritating red spots on his foot, but did not recognize them as an epichlorohydrin burn and put the leather boot back on his foot. The following morning, the worker awoke with a very swollen foot and a large blister across the area where the irritation was first observed. A medical investigation indicated that he had a severe burn which was believed to be caused by the very small epichlorohydrin exposure that occurred on the previous day. The burn required skin grafts and eight weeks to heal. This incident reinforces the following observations:
• Leather does not offer suitable

protection when handling epichlorohydrin and may magnify the burn potential. • Even an apparently insignificant

exposure can lead to a serious burn if the contact continues for an extended period of time. • After leather is contaminated, it

cannot be decontaminated and therefore must be destroyed. • The specific manufacturer’s data on

personal protective clothing (e.g., gloves, boots, and slicker suits) should be reviewed to ensure their suitability for use. • All terminal valves and fittings

should be plugged to reduce the likelihood of an accidental
exposure. 

### Carcinogen Potential Epichlorohydrin has been shown to cause cancer in laboratory animals. In the U.S.A. it is considered to be a potential carcinogen for purposes of the Occupational Safety and Health Administration’s (OSHA) hazard communication standard, 29 CFR 1910.1200. It is classified by the International Agency for Research on Cancer (IARC) as 2A (probably carcinogenic in humans). The American Conference of Governmental Industrial Hygienists (ACGIH) classifies epichlorohydrin to cancer class A3 (confirmed animal carcinogen with unknown relevance to humans). Health, Safety, and Handling14 In Europe, the Dangerous Substances Directive 67/548/EEC and the updates thereto classify epichlorohydrin as a Category 2 carcinogen (carcinogenic in animals). The directive further requires the description of epichlorohydrin as follows: “The substance should be regarded as if it is carcinogenic to man. There is sufficient evidence to provide a strong presumption that human exposure to the substance may result in the development of cancer.” Various epidemiological studies, however, have not supported the contention that epichlorohydrin is carcinogenic to humans. For more information refer to the following

resources:

• Retrospective Cohort Mortality

Study of Workers With Potential Exposure to Epichlorohydrin and Allyl Chloride. G.W. Olsen, et al., American Journal of Industrial Medicine, (1994), 25(2), 205-18

• IARC report Vol. 71 (1999) p 603,

Section 5 Summary of Data Reported and Evaluation, available at http://www-cie.iarc.fr htdocs/ monographs/vol71/020- epichlorohydrin.html



### Preventive Examinations Before workers are assigned to epichlorohydrin handling operations, they should be screened with a complete pre-placement examination.
Note: Individuals with medical conditions that involve impairment of the liver, kidney, heart, or respiratory tract (which may include impairment due to abuse of alcohol) may be restricted from being assigned to jobs where exposure to epichlorohydrin could occur and create additional organ stress. For all workers assigned to positions where epichlorohydrin exposure could occur, annual examinations with special attention to lung, liver, and kidney functions are suggested.



### Handling Instructions All employees involved in the handling of epichlorohydrin should receive instructions before they start working with this substance. These instructions should be about the specific hazards of this chemical and decontamination procedures in the event of overexposure. Assistance with worker training is available from Dow.
Workers should be cautioned not to breathe epichlorohydrin vapor. Odor does not give adequate warning of an overexposure situation (see “Odor Threshold” on page 12). Any symptoms of exposure to epichlorohydrin, such as eye or respiratory irritation and skin rashes, should be reported immediately. Do not wear leather articles such as shoes, belts or watch bands, since leather cannot be decontaminated and can increase localized burn potential by holding the epichlorohydrin against the skin. Contaminated shoes or other articles of clothing should be removed immediately. Note: Be sure to physically destroy any such contaminated article to ensure that it is not reused by other individuals.



## Decontamination, First Aid, and Physician Notes

In the Event of Exposure • Remove the patient from the

exposure area immediately. • Start thorough decontamination

procedures at once. • See a physician. 

### Decontamination • Eye exposure requires immediate

and thorough decontamination by irrigating the eye with low-pressure water continuously for at least 15 minutes. • Skin contact with the liquid is

irritating and capable of causing skin burns. Skin exposure requires immediate showering with copious amounts of water for at least 15 minutes. Use soap if available. • Contaminated clothing should be

removed immediately, while showering. The clothing should be destroyed and not be re-used. • Leather goods (shoes, belts, and

other) cannot be decontaminated. Contaminated leather goods should be physically destroyed to prevent accidental reuse.



### First Aid • Remember, if respiratory distress

develops, move the affected person to fresh air. If the person is not breathing, give artificial respiration. If breathing is difficult, oxygen should be administered by qualified personnel. • Do not induce vomiting. Call a

physician and/or transport to an emergency medical facility. • Never give an unconscious person

anything by mouth or attempt to induce vomiting. • In all cases, secure medical

attention at once.


### Physician Notes Skin contact with the liquid is irritating and capable of causing delayed skin burns. These may escalate to deep second-degree burns with little or no warning. If a burn is present, treat it as any thermal burn after decontamination. Health, Safety, and Handling15 Repeated skin contact even at a low dose can lead to sensitization and allergic reactions. If respiratory distress develops, rest and oxygen administration may be helpful. Lung function should be assessed following a significant single or intermittent inhalation exposure. Persons receiving significant exposures should be observed for 24- 48 hours for signs of respiratory distress. Any significantly exposed individual should be monitored for liver and kidney function for at least 60 days. Treatment is symptomatic and supportive if liver or kidney injury occurs. Chemical burns of the eye should be treated by a physician experienced in dealing with chemical eye injuries, but only after immediate and adequate decontamination with

water. If lavage is performed, endotracheal and/or esophageal control is suggested. Danger from lung aspiration must be weighed against toxicity when considering emptying the stomach. There is no specific antidote for epichlorohydrin. Provide supportive care. Treatment should be based on the judgment of the physician and the patient’s reactions.


### Exposure Limits Government exposure limits are subject to periodic revision. The information in Table 4 is given in good faith and believed to be correct as of April 2006. Note: The National Institute for Occupational Safety and Health (NIOSH) listing for the vapor concentration considered immediately dangerous to life and health (IDLH) is 75 ppm for Health, Safety, and Handling epichlorohydrin (see the NIOSH Pocket Guide to Chemical Hazards, or visit their website at www.cdc. gov/niosh/npg/npg.html.
Further information on the health and environmental effects of epichlorohydrin can be reviewed on the International Programme on Chemical Safety (IPCS) INCHEM document: www.inchem.org/ documents/ehc/ehc/ehc33.htm.


### Exposure Control Although epichlorohydrin has a very high vapor pressure, it can be controlled to maintain vapor concentrations well below occupational exposure limits (see Table 4). This should be achieved through properly designed, leak-tight product handling systems. Good ventilation is important; whenever possible, the epichlorohydrin handling facilities should be located outdoors to maximize natural ventilation. However, good ventilation cannot replace a closed, leak-tight system. Dow people have extensive experience in this area and are prepared to help you evaluate proposed equipment designs. We can also provide information about the equipment used in our operations (see “Storage and Equipment,” page 31). All aspects of the handling operation, from delivery through reaction to disposal, must be carefully scrutinized for exposure potentials. Activities such as sampling should receive particular attention. Measures that prevent exposures should be thoroughly explored. These include the use of vapor return lines during product transfer, the dry disconnect style of fittings for transfer hoses, automated sampling systems, and the like. Systems also must be designed to accommodate safety showers and eye washes in the immediate area (less than 8 meters [26 feet] apart) where exposures are likely, such as truck or rail car off-loading stations and locations where samples are taken. Showers and eye washes should be located so that workers whose vision is impaired by an exposure can easily find them. When respiratory protection is required for certain operations, use an approved full face air-purifying respirator or a positive-pressure supplied-air respirator, depending on the potential airborne concentration. If air-purifying respirator is used, it should be fitted with a fresh canister for organic vapors or organic-vapor/ acid-gas combinations.
Note: Used canisters should bedestroyed due to the poor odorwarning properties of epichlorohydrin which make odor an unreliable indicator of chemical breakthrough.
For emergencies and other conditions in which the exposure guideline may be greatly exceeded, use an approved positive-pressure self-contained breathing apparatus (SCBA) or a positive-pressure supplied-air respirator with an auxiliary SCBA.
Tanks and reactors must not be entered until they have been washed, purged, and tested for the presence of epichlorohydrin vapor (see proposed washing and tank entry procedures in section “Storage and Equipment,” page 31). Safe oxygen concentrations (19.5-23.5 percent) should be demonstrated with an oxygen

meter test.16 

### Table 4: Regulatory Occupational Exposure Limits for Epichlorohydrin (1) Health, Safety, and Handling

Country 8-Hour TWA (ppm) 15-min STEL (ppm) Ceiling (ppm) Notes Argentina 0.5 A3; Skin Austria 3 12 Skin, Sensitizer, Carcinogen A2 Australia 2 Skin, Carcinogen C2 Belgium 2 Skin, Carcinogen Bulgaria 2 Skin, Irritant, Allergenic, Carciogen C2 Canada - Ontario 0.5 Skin Canada - Quebec 2 Skin Canada-Alberta 0.5 Skin. Use more restrictive of day or week adjustment. Exposure can't exceed 3 times the 8-hour OEL for more than a total of 30 minutes during a continuous 24-hour period, and 5 times the 8-hour OEL at any time. Canada-B.C. 0.1 Skin Canada-Manitoba 0.5 China 0.26 0.53 Skin Columbia 0.5 Skin, A3 Croatia 2 Skin, Irritant, Allergenic, Carciogen C2 Czech Republic 0.26 0.53 Skin, Sensitizer Denmark 0.5 Skin Estonia 0.5 1 Skin, Sensitizer, Carcinogen Finland 0.5 Skin France 2 Skin, C2 Greece 2.5 5 Skin Hong Kong 0.5 Skin; A3 Hungary 0.5 Skin, SEN Iceland 0.5 Skin, Sensitizer, Carcinogen Indonesia 2 Skin Ireland 0.5 1.5 Skin, Carcinogen C2 Italy 0.5 Skin Korea 2 Latvia 0.26 Allergenic, Carcinogen Lithuania 0.5 1 Skin, Sensitizer, Carcinogen Malaysia 0.5 Skin Mexico 2 5 Skin Netherlands 0.5 New Zealand 0.5 1.5 Skin, Carcinogen A3 Norway 0.5 Skin, Semsitizer, Carcinogen Peru 0.5 Skin, A3 Philippines 5 Skin Poland 0.26 Portugal 5 Skin, Carcinogen A3 Romania 0.26 1.4 Skin, Potential Carcinogen Russia 0.3 Skin, All Russian Federation 0.26 0.53 Skin, Allergen Serbia & Montenegro 2 Skin, Carcinogen Singapore 2 Slovakia 3 Skin, C2 Carcinogen Slovenia 3 12 Skin, Carc2 South Africa 0.5 1.5 Skin; ALARA Spain 0.5 C2; posibilidad de sensibilizacion en contacto con la piel; Skin Sweden 0.5 1 Skin, Carcinogen; Sensitizer Switzerland 2 Skin, Sensitizer, Carcinogen Taiwan 2 Skin United Kingdom 0.5 1.5 U.S.A. - California 2 Skin U.S.A. - North Carolina 2 Skin U.S.A. Federal OSHA 5 Skin Venezuela 0.5 Skin, A3 

### Non-Regulatory Exposure Guidelines (1)

ACGIH Threshold 0.5 Skin, A3 (irritation, liver and kidney effects) Limit Value ® (TLV) - 1997 to Present

(1) TLVs are appropriate guidelines to use where regulatory OELs do not exist.
Source: ARIEL Database by 3E Company: January 200717 

### Air Monitoring Due to its toxicity, high vapor pressure, and corrosive nature, epichlorohydrin can be safely handled in closed systems only. Because epichlorohydrin can be absorbed through the skin in toxic quantities, it is particularly important to avoid skin contact with vapor or liquid. All operations must be designed with engineering controls to minimize personnel exposure (see “Storage and Equipment,” page 31). Operations such as sampling, which are often considered “open-system” operations, should also be designed to avoid exposure. To ensure that epichlorohydrin is effectively contained, a formal air monitoring program should be designed and implemented by a qualified industrial hygienist. This is particularly important for epichlorohydrin, which has poor odor-warning properties (see “OdorThreshold,” page 12). The odorwarning properties are not adequate indicators of an over exposure potential. The industrial hygienist should consider all aspects of the operation, including work environment and job tasks. When changes are made in procedures or equipment, sampling should be performed to verify containment. A Dow industrial hygienist can assist with air monitoring and help determine exposure levels in your operation. Talk with a Dow representative for more information. 

## Personal Protective Equipment All system designs should focus on eliminating the need for personal protective equipment. However, personal protective equipment may be required in certain operations, or in areas where exposure to vapor or liquid is possible, such as in the event of a system failure. The selection and use requirements of personal protective equipment demand careful management consideration. An overall appraisal should be made of the plant operation, exposure potentials, expected exposure duration, the specific activities being performed, and the training on personal protective equipment being provided to workers. This appraisal should be performed by a qualified industrial hygienist in conjunction with engineering, maintenance, supervisory, and management staff. An overall written plan to control exposures should be developed. The plan should identify the types of approved equipment (including manufacturer, make, and model); the types of protective equipment to use for specific situations; the procedures for maintenance, cleaning, and storage of the protective equipment; required training; and other issues. Issues to consider when selecting personal protective equipment and managing equipment programs include: • Is there a practical way to reduce

the expected exposure by changes in either equipment use or procedures? • Is the exposure likely to be at levels

above the occupational exposure limits (see Table 4)? • Is the exposure likely to be of very

short duration, after which decontamination can be immediately accomplished, or will a lengthy exposure occur? • Is the exposure likely to occur only once or twice per month as might occur in some unloading operations? • Is single-use equipment desirable? Note: The MSDS/SDS on epichlorohydrin suggests that air purifying respirators, supplied air, or self-contained breathing apparatus (SCBA) be used depending on conditions when respiratory protection is required.



### Protective Clothing Even well-engineered systems will require the use of personal protective clothing in the event of spills or other potential exposure situations. In all operations involving epichlorohydrin, and where employee exposure is possible, workers should wear chemical workers’ goggles, safety hats, impervious boots, gloves,and outer clothing (full bodycovering impervious suits). Trousers should be worn outside the boots and sleeves should be taped to gloves (with tapered sleeve inserts between sleeve and glove) to prevent contact of epichlorohydrin with the skin. Clothing type, make, and materials of construction should be carefully evaluated using an “exposure control management” approach that evaluates each exposure situation. For example, protective clothing for splash protection (which is disposed of or immediately cleaned after exposure) may not need to be as durable as protective clothing for continuous exposure situations. Carefully evaluate the data that is supplied by your clothing manufacturer, paying particular attention to the expected clothing performance upon exposure to epichlorohydrin. Important selection criteria are a high breakthrough time and a low permeation rate (see Table 5). Health, Safety, and Handling18 TM Trademark of The Dow Chemical Company (“Dow”) or an affiliated company of Dow It is important to recognize the hazards associated with each material choice. For example, leather is a hazard when contaminated and should not be specified for use. It can absorb epichlorohydrin and maintain a low exposure level over a prolonged period of time, causing a severe burn before discomfort registers. Such burns have been serious enough to require skin grafts. It is also necessary to set guidelines for decontaminating and destroying protective clothing. Leather articles should be destroyedto prevent accidental reuse. Note: Personnel should be required to wear “work” clothes and to store them separately from their “street” clothes. This allows the industrial laundry to handle and wash work clothes that could be chemically contaminated.



### Impervious Clothing When choosing impervious protective clothing, the intrinsic barrier properties like breakthrough time and permeation rate are factors to consider. Other factors that affect performance include: • Physical strength, abrasion

resistance, or tear resistance required in specific use conditions; • Thickness of the material; • Fabrication technique (e.g. sealing

of seams). Dow suggests that customers obtain information from clothing and equipment suppliers about the performance of their products in given situations and the barrier properties to epichlorohydrin. You may also want to consult the Dow MSDS/SDS. 

### Protective Equipment Training Training of personnel on the use of protective equipment is the key to a successful program. Without a good understanding of the way the protective equipment works and its limitations, and the correct maintenance procedures, the expected protection factors are unlikely to be achieved. Specific issues such as the toxicity of epichlorohydrin vapors via the skin and the protection required should be part of the training program. Training must also review the proper way to wear, use, clean, and maintain each piece of equipment. The use of respirators, for example, should require medical approval for the individual and a fit-test to ensure effective protection. Training should be documented and reviewed with the employee(s) on a regular basis with retraining on a specified and annual basis. Health, Safety, and Handling



### Table 5: Clothing Parameters
Item Considerations Clothing, Gloves, Boots Butyl rubber appears to provide the best inherent barrier properties. Laminate constructions containing SARAN TMResins or polyvinyl alcohol can be designed to provide various levels of barrier. Nitrile and neoprene rubber are penetrated more readily. Respiratory Protection Where low short-term exposures are anticipated, use full face respirator with organic vapor or organic vapor/acid gas cartridges. For unknown concentrations to those substantiallyabove the occupational exposure guide, use positivepressure supplied air or self-contained, positivepressure breathing apparatus (SCBA).For emergency situations use self-contained, positivepressure breathing apparatus. Eye Protection Chemical workers ’goggles, if splashes of epichlorohydrin are unlikely to occur. Full face shield if splashes may occur. Alternatively, a full face respirator can be used.
Note: Latex, PVC, natural rubber (household) glove materials have only very limited protection properties. These materials are readily penetrated and give less protection.19 

### Figure 5: AZ-Armaturen Sampling System

Perhaps the best place to take the sample is from the line through which the vehicle will be off-loaded. Note: The use of the sampling port provided within the dome on rail cars in North America will usually produce a non-representative sample because the line is often stagnant for long periods of time (the usual problems with samples from the stagnant line are high color and non-volatile matter). If the sample port is to be used, sufficient purge to completely clear it will be required.
Another approach to verifying the contents of a delivery vehicle is to sample the atmosphere in the vehicle and test it for epichlorohydrin. The vent sample can be taken in a purged sample bomb connected to the vehicle vent. If the sample is taken from the vapor return line, care must be taken to ensure that the sample is representative of the vehicle contents and not of the line. Health, Safety, and Handling



## Sampling of Delivery Vehicles Sampling and analysis of the delivery vehicle is the surest way to verify that the product is epichlorohydrin. Sampling systems must be designed to avoid operator exposure. Many such systems are commercially available from specialty equipment suppliers; some suppliers will design a system specifically for your purposes. The systems vary from simple and low cost to very highly automated and expensive systems. Other systems of a less automated nature are also available that control exposures, but require more operator training and care. An example of a simple, but safe and effective sampling system which is commercially available is shown inFigure 5. It is available from AZArmaturen, www.az-armaturen.de.20 

### Venting of Delivery Vehicles Adequate venting of delivery vehicles is an important safety practice during off-loading of epichlorohydrin. Inadequate venting can result in the collapse of the vehicle. Points to consider include: • At normal off-loading rates, the

industry standard 3/4-inch vacuum relief valve on delivery vehicles is not sized to provide enough air flow to prevent catastrophic failure of the trailer barrel. Typically 15 kPa (2-3 psi, 0.13 bar) negative pressure will cause failure; • The collapse of the tank not only

represents a serious safety issue and financial loss, but also can potentially lead to a tear in the side wall of the tank, which would likely result in the unavoidable spill of the truck’s remaining contents; • There are significant examples of

catastrophic collapse of tanks which were not adequately vented during off-loading (see Figure 6). 

### Figure 6: Effects of Vacuum on a Rail Car and a Storage Tank



### Customer Actions
Dow recommends that customers take these actions: • Evaluate the pressure drop at the maximum expected off-loading rate for

each vent system being used; • Ensure that the vent system is designed to keep a positive pressure or no

more than 7 kPa (~1 psi) negative pressure on the delivery vehicle; • Employ flow- and pressure- measurement devices on the vent line tied to

shutdowns of the transfer equipment; • Develop written procedures for off-loading, including a checklist of critical

actions to ensure venting.

Note: A closed loop gas return line of sufficient diameter (min. 5 cm / 2 inches) from the customer’s storage tank gas phase to the delivery vehicle gas phase is the preferred configuration. Health, Safety, and Handling21 

# A lthough the chemical industry has one of the highest safety records, it is very important to put an effective, well-developed plan in place to ensure quick and effective response to emergencies. Emergency preparedness should consider all aspects of emergency situations that may occur on the site, in the surrounding community, or in the community at large. This section describes a process for emergency planning and provides specific information about spills, fire-fighting, and associated waste disposal. Plans should be developed with the assistance of local fire-fighters and community groups. Several resources are available from the International Council of Chemical Associations (ICCA), www.icca-chem.org; the American Chemistry Council (ACC), www.americanchemistry.com; and the European Chemical Industry Council (CEFIC), www.cefic.org. 

# Emergency Preparedness

Table 6: Chemical Manufacturers’ Organizations in Other Countries

Australia Plastics and Chemicals Industries Association (PACIA) www.pacia.org.au

Brazil Asso ç iac ã o Brasileira da Industria Quimica e de Produtos www.abiquim.org.br Derivados Abiquim
Canada Canadian Chemical Producers ’Association (CCPA) www.ccpa.ca India Indian Chemical Manufacturers Association (ICMA) www.icmaindia.com Japan Japan Chemical Industry Association (JCIA) www.nikkakyo.org/organizations/jrcc/ index.html
Mexico Asociaci ó n Nacional de la Industria Quimica AC (ANIQ) www.aniq.org.mx South Africa Chemical and Allied Industries Association (CAIA) www.caia.co.za

DOW TM Epichlorohydrin 

## Plan Development The first step in emergency planning as defined by the ACC is crisis management planning. This begins with a definition of potential crises that require planning, and then moves through a number of steps related to planning, preparation, mobilization, response, recovery, and post-incident follow-up. The procedure should be comprehensive and consider all aspects of potential emergencies, including warning alarms, evacuation assembly areas and escape routes, personnel accountability, communication vehicles, chain of command, notification of authorities, dealing with the media, and other important concerns. If your plant does not have a crisis management plan, one should be developed.

TM Trademark of The Dow Chemical Company (“Dow”) or an affiliated company of Dow22 If we assume that a general emergency plan exists for your facility, the task of preparing for a new installation starts with a proper design. Engineers should design the bulk storage and handling system to prevent hazardous conditions and to allow quick response if emergencies occur. For example, Dow requires the use of nitrogen padding on epichlorohydrin storage tanks to eliminate oxygen from the tank and thereby reduce the risk of fire. An excellent way to test a new design is to perform a process hazard analysis. For assistance, refer to a process safety management publication, such as that developed by the ACC. The ACC publication suggests methods to identify, assess, control, and manage hazards. As part of the hazard identification and management process, it is also important to define safe operating procedures. Helpful resources include:

• Crisis Management Planning for

the Chemical Industry, Manual and Videotape, 1992, Order No. 022012, CMA.

• Site Emergency Response Planning

Guidebook , 1992, Order No. 024041, CMA.

• Process Safety Management

(Control of Acute Hazards) , 1985, Order No. 047023, CMA.

• A Resource Guide for

Implementing the Process Safety Code of Management Practices
, 1990, Order No. 047024, CMA. To obtain these resources, write to: American Chemistry Council 1300 Wilson Boulevard Arlington, VA 22209 U.S.A. Phone: +1 (703) 741-5600 After completing both an overall crisis management plan and a process hazard analysis, the next logical step is to develop written procedures for responding to possible emergencies associated with the new installation. These plans must be carefully tied into the emergency plan and cover all of the aspects required in the overall plan. The procedures should also include a specific plan for controlling the emergency. Procedures should cover all parameters, including fire extinguishers and similar equipment, emergency block valves, spill containment, personal protective equipment and clothing, and so on. All post-emergency procedures, such as waste clean-up, waste disposal and equipment checks, should also be considered. The plan should be tested in a simulated situation to ensure its effectiveness in a real emergency. The third step in developing an emergency plan involves community interaction. The plan should be integrated into the community-wide emergency response plan. If your community does not have a plan that integrates industrial and civil emergencies, refer to the Community Awareness and Emergency Response (CAER) guide from the American Chemistry Council (ACC) or from the European Chemical Industry Council (CEFIC). CAER is a Emergency Preparedness

chemical industry initiative supported throughout the world through Responsible Care ®

. If your community does not have a plan that integrates industrial and civil emergencies, refer to the sections Community Awareness and Emergency Response of the Responsible Care principles by the International Council of ChemicalAssociations (ICCA), www.iccachem.org. 

## Transportation Emergency

Within the framework of Responsible Care, Dow and its carriers make every effort to transport goods to and from its manufacturing sites and storage locations safely and in full accordance with relevant regulations and codes of practice. In the event of an incident, the chemical industry will provide information, practical help and, if necessary and possible, appropriate equipment to the competent emergency authorities in order to minimize any adverse effects.

®Responsible Care is a service mark of the American Chemistry Council in the United States CMA (Chemical Manufacturers Association) has been renamed ACC (American Chemistry Council).23 

### North America CHEMTREC (CHEMical TRansportation Emergency Center), www.chemtrec.com, is committed to providing emergency response personnel, law enforcement agencies, and other interested persons with information necessary to better mitigate emergencies associated with hazardous materials.


### Europe ICE (International Chemical Environment, European Emergency Response Network) www.cefic.org/ activities/logistics/ice/ice-guide.htm, is a cooperative program between chemical companies to prevent chemical transport incidents and to respond effectively if and when they do occur.



### Other Countries Please refer to country-specific emergency organizations (see Table 6). 

## Fire-Fighting Guidelines

Fire Hazards Epichlorohydrin is a flammable liquid and its vapor forms explosive mixtures with air. Although the lower limit for oxygen concentration for epichlorohydrin flammability is 11.6 percent, Dow requires the concentration to be below 8 percent as a safety factor.



### Hazardous Combustion Products During a fire, smoke may contain the original material in addition to combustion products of varying composition which may be toxic and/ or irritating. Combustion products may include and are not limited to: Hydrogen chloride. Carbon monoxide. Carbon dioxide. Emergency Preparedness



### Table 7: Flammability Limits for Epichlorohydrin

Flammability Limits LFL UFL Lower Limit Upper Limit Epichlorohydrin in Air 3.8 % 21 % Oxygen in Epichlorohydrin Vapor 11.6%

– The flash point of epichlorohydrin is 31 ̊C (88 ̊F), Tag Closed Cup (TCC). Exotherm begins at 325 ̊C (617 ̊F) and the auto-ignition temperature is 416 ̊C (781 ̊F). The vapor is heavier than air and may travel considerable distance to a source of ignition and then flash back. The material is moderately soluble in water (6.6 percent at 20 ̊C/68 ̊F).


### Fire-Fighting Methods Use water fog, dry chemical, alcohol foam, or carbon dioxide when fighting fire. Use water to keep fire-exposed containers cool. If a leak or spill has not ignited, use water fog to disperse the vapors and to provide protection for workers attempting to stop a leak. Water fog may be used to flush spills away from potential ignition sources. Wear a positive-pressure, self-contained breathing apparatus if contact with the vapors is possible; wear full protective clothing (see “Health, Safety, and Handling” on page 12). For more information, review the local and country codes for fire protection such as the National Fire Protection Association (NFPA), www.nfpa.org, the European EN standards or the global International Electrical Council standards (IEC).



### Table 8: Fire Protection Standards Item North America Europe Pacific WorldwideFlammable and NFPA No. 30 EN standards CountryCombustible Liquids specific standards Electrical Codes NFPA No. 70 EN standards Country- IEC standards specific standards Protection Codes NFPA No. 780 EN standards Country- IEC standards specific standards –24 

## Spill Clean-Up

Degradation in the Environment Epichlorohydrin is slightly toxic to aquatic organisms and moderately toxic to algae. It may also be moderately toxic to mammalian wildlife. Epichlorohydrin is a mobile, volatile liquid with a water solubility of approximately 6.6 percent (66 g/l). Epichlorohydrin hydrolyzes in distilled water at a rate of 9.75 x 10 -7 s -1 , which corresponds to 50 percent hydrolysis in 8.2 days (see Mabey and Mill resource below). It also reacts with other nucleophiles such as chloride or hydroxide, which could lead to a more rapid hydrolysis. Dow studies, in addition to other work by W. Mabey, T. Mill, A.L. Bridie, and S. Sasaki (see resources below), indicate that biodegradation is a major environmental process with 5-day Biological Oxygen Demand (BOD) values of 18 percent (Dow) and 14 percent (acclimated; Bridie). Biodegradation continues with BOD values of 43 percent and 53 percent after 10 and 20 days, respectively (Dow) and is significantly degradable in the Japanese Ministry of International Trade and Industry test (Sasaki). Biodegradation can also take place in surface soil. The high water solubility and mobility makes it possible for epichlorohydrin to enter the ground water where biodegradation is expected to continue, but at a slower pace. The hydrolysis of epichlorohydrin will prevent it from being a ground water pollutant other than immediately after a large spill. In the aquatic environment, epichlorohydrin will hydrolyze, biodegrade, and volatilize. Emergency Preparedness

In a wastewater treatment system, the same processes will take place, with hydrolysis playing a minor role due to the short residence time. Overall, epichlorohydrin is relatively unstable in the air and water. However, when spilled, it may exert a toxic action before hydrolysis. Epichlorohydrin is inherently biodegradable and the bioconcentration potential is low. Contamination of soil and water should be minimized by spill containment and removal, whenever possible. For more information, review the Dow MSDS/SDS or the following studies:

• Critical Review of Hydrolysis of

Organic Compounds in Water Under Environmental Conditions
, W. Mabey and T. Mill, J Phys. Chem. Ref. Data 7, 383-415 (1978); quoting J.N. Bronsted and M. Kilpatrick, J Amer. Chem. Soc., 51, 428 (1929).

• BOD and COD (Chemical

Oxygen Demand) of Some Petrochemicals , A.L. Bridie, C.J.M. Wolff, and M. Winter, Water Res., 13, 627-630 (1979).

• Aquatic Pollutants: Transformation

and Environmental Effects
, S. Sasaki, O. Hytzinger et.al.eds., Pergamon, Oxford pp. 283-298, (1978). 

### Absorbents Dry sand or ground polypropylene materials are suitable absorbents for epichlorohydrin spills. The advantage of polypropylene-based absorbents lies in their ability to be incinerated without creating a large ash loading on the incinerator. Two specific polypropyleneabsorbents tested by Dow are HazMat Pig and Polysorb from New Pig Corp., One Pork Ave., Tipton, PA 16684-0304, U.S.A., www.newpig. com; and Lab Safety Supply Inc., P.O. Box 1368, Janesville, WI 53547-1368, U.S.A. Clay-based absorbents should not be used since they react with the epichlorohydrin resulting in the evolution of heat. Heat from this reaction can result in spontaneous combustion since auto-ignition temperatures can be reached. Other absorbents may be suitable, but should be tested prior to use for reactivity with epichlorohydrin. For large spills, clean-up is often best handled with a vacuum truck. If this approach is used, the truck should be padded with an inert gas before vacuuming the spill. Care should be taken not to introduce air into the truck as liquid is vacuumed. This could create an explosive atmosphere in the vacuum truck. Consider that the vent of the vacuum truck will emit significant amounts of epichlorohydrin vapor, which could cause additional hazards (environmental or health). The possibility of a two-phase water mix must be considered; the hazard caused by a reaction with epichlorohydrin can occur over time. Note: Suppliers and their products identified in this Manual are referred to in good faith, but no endorsement is made. It is the customer’s responsibility to research available suppliers and make the appropriate selection.25 

## Waste Disposal Epichlorohydrin is classified as a hazardous waste in any part of the world. The relevant country-specific MSDS/SDS should be consulted for specific government requirements related to waste disposal. Customers are advised to check their local applicable government requirements. Several methods of disposal areavailable, including incineration, biotreatment, and chemical conversion. Applicable government requirements must be considered prior to selecting a method. Final disposal methods should be discussed with local authorities whenever possible. All applicable government requirements regarding health, environment, and waste disposal must be observed. Contact Dow for additional information. All quantities of epichlorohydrin - or waste material contaminated with epichlorohydrin - should be removed to an approved industrial waste disposal area. If epichlorohydrin is to be incinerated, only an approved incinerator suitable for handling chlorinated hydrocarbons can be used. During incineration, hydrogen chloride is produced and must be scrubbed out of the gas from the incinerator.
Water contaminated with epichlorohydrin should be drained to a controlled area. This contaminated water should be treated at an approved water treatment facility. When a problem arises as a result of a major spill or equipment rupture, only properly protected and trained personnel should remain in the area to supervise response and cleanup. 

### Hydrolysis The alkaline hydrolysis of dilute water solutions of epichlorohydrin to glycerine can, under certain circumstances, be a desirable way to handle very small quantities of waste.


### Table 9: Epichlorohydrin Half Life, (T 1/2) in water @ pH 7

Temperature ( ̊C) T 1/2 (h)

20 160

30 5 In a solution of 4N NaOH, the highest reaction rate can be expected (half-life approximately 15 minutes). Note: The hydrolysis reactions of epichlorohydrin generate heat and a pressure build-up is a serious concern if the reaction is done in a contained system. Under alkaline conditions, the hydrolysis of epichlorohydrin proceeds to glycerine through an intermediate: glycidol. 2,3-Epoxy-propan-1-ol (note that glycidol is also toxic). The reaction rate is relatively slow at room temperature and can take days or weeks, depending upon circumstances, to proceed completely to the final product, glycerine. The reaction rate increases at elevated temperature. Treating large amounts (>100kg) of epichlorohydrin with dilute alkali at ambient temperatures with subsquent heating can lead to an uncontrollable polymerization with excessive heat generation. If hydrolysis is considered, tests should be run to determine the exact chemical make-up of the resulting mixture before proceeding with disposal. Large amounts of epichlorohydrin should be disposed of in an incinerator.
Note: Do not use sodium carbonate or other alkali as an absorbent for spilled epichlorohydrin.
If removal of trace quantities of epichlorohydrin from equipment is the objective, the use of low- or medium-pressure steam should be considered as the first means to react it. Hydrolysis at ambient temperatures at neutral or acid pH is not suggested because the reaction beyond the initially-formed chlorohydrins proceeds slowly. Contact your Dow representative if you wish additional information or assistance. Emergency Preparedness26 

# T his section reviews road shipments and rail shipments, and provides a delivery checklist for customer use. Prior to delivery, customers should be prepared to safely receive and off-load DOWTM Epichlorohydrin.
Note: Dow will not make deliveries to sites with which we are not familiar or are not assured that personnel are capable of safe unloading and storage. In general, this means that Dow will not deliver to a site that has not been visited and reviewed by a Dow representative. Upon request, Dow technical personnel will review the engineering plans of a proposed new facility and provide feedback and suggestions.
It is important to carefully instruct all personnel involved in the handling of epichlorohydrin (including unloading operators) on the hazardous properties of this material. Because the degree of hazard in handling or unloading epichlorohydrin varies from one operation to another, individual situations should be carefully evaluated to determine the appropriate safety measures. Epichlorohydrin is supplied in bulk quantities only. However, small samples (typically 0.5 liter) are also available after a screening process has ensured that the person requesting the sample is aware of the material’s hazards and can handle the material safely. Bulk shipments are available in truck, rail car, barge, ship, and Intermodal ISO-containers as required. All bulk vehicles are designed to handle a closed-loop vent return from the storage tank. The vehicles in North America are also designed with a dry break fitting on both the vapor return line (1.5-inch) and the liquid off-loading lines (2-inch) to facilitate an exposure-free transfer of product. These dry break fittings are very effective at reducing the spillage during connection and disconnection to only a few droplets of fluid. The dry break feature requires that customers have a matching fitting (see “Storage and Equipment,” page 31).



### Figure 7: Dry Disconnect Style Fittings

1. Comes attached to bulk delivery vehicle off-loading line.
2. Connect to flexible hose. 

# Delivery Procedures

TM Trademark of The Dow Chemical Company (“Dow”) or an affiliated company of Dow DOW TM Epichlorohydrin27 Parts shown are: • 1676 AN-SS-20 2-inch (5.08-cm) stainless steel adapter with female National Pipe Thread and Chemraz seals • 1773 D-SS-20 2-inch (5.08-cm) stainless steel coupler with female National Pipe Thread and Chemraz seals
Parts not shown are: • 1676 AN-SS-15 1-1/2-inch (3.81-cm) stainless steel adapter with female National Pipe Thread and Chemraz seals • 1773 D-SS-15 1-1/2-inch (3.81-cm) stainless steel coupler with female National Pipe Thread and Chemraz seals
Photo courtesy of Civacon, P.O. Box 54907, Cincinnati, OH 45254, U.S.A., +1 (513) 528-2700 

## Road Shipments For road truck deliveries in North America, Dow uses a dedicated fleet of trucks owned and managed by a single carrier. This carrier employs only drivers who have received extensive training about the properties and hazards of epichlorohydrin and the procedure in which delivery equipment must be handled for a safe, spill-free delivery. These drivers can be a very useful resource to assist your operating personnel with trouble-free transfers. In Europe and other regions, the truck quantity deliveries are made in dedicated intermodal containers (“ISO-containers”, 23 metric tons, volume 25,000 liters) by a single carrier. A program of carrier appraisal and driver training is also in place. ISO-containers can be unloaded either from the top or from the bottom. The standard valves sizes on the top are DN80 for liquid and DN50 for vapor.The standard bottom valve type of an ISO-containers is a 3-inch BSPcoupling. To minimize personnel exposure to epichlorohydrin, Dow requires customers to use their own dedicated hose permanently attached to their pumping system. For this reason, Dow does not supply hoses or truck pumps. Dow Product Stewards can provide product safety training for your employees, and will also attend your first delivery. Talk to your Dow representative or call your nearest Dow location for assistance. 

## Rail Shipments Dow also ships product in a dedicated fleet of rail cars. These cars are 20,000 gallon (80 metric tons) pressure cars set up for top off-loading only. In North America, these cars are all fitted with dry break fittings for both liquid and vapor return. The fitting size is 2 inches for liquid and 1.5 inches for vapor. The dedicated rail cars in Europe can load 65 metric tons (70 m 3volume) and are designed for top and bottom discharge. The sizes of the connection flanges in Europe are DN100 for liquid and DN50/DN80 for vapor. Rail cars are not used in regions other than North America and Europe. Delivery Procedures28 Delivery Procedures 

### Table 10: Fitting Sizes for all Means of Transport Means of Transport Region Liquid Gas Remarks Rail car North America 2-inch 1.5-inch Dry-break coupling Europe DN100 DN50/DN 80 Standard flanges (Top and bottom discharge) Road Truck North America 2-inch 1.5-inch Dry-break coupling Europe – – Not supported
Intermodal Container (1) North America 2-inch 1.5-inch Dry-break coupling Europe Top: DN100 DN50/DN80 Top: Flange Bottom: 3-inch BSP See Figure 8 Vessel / Barge – – – On request

(1) Intermodal containers are the preferred shipping mode for epichlorohydrin into other global regions. Contact our Customer Information

Group (CIG) for more information.

Photo courtesy of HOYER GmbH Hamburg, Germany, www.hoyer-group.com 

### Figure 8: Container Bottom Valve, 3-inch BSP

Figure 9: Container Top Connections, DN50 and DN80 Figure 10: Rail car Top Connections

Photo courtesy of VTG AG, Germany, www.vtg-rail.de29 

## Delivery Checklist The following checklist is designed to help you prepare for a first delivery of either a bulk truck, ISO-container or a rail car to a new facility. For specific information about hardware, see “Storage and Equipment” on page 31, or talk to your Dow Product Steward.
• Has a Dow Product Steward visited

your facility and reviewed your bulk epichlorohydrin handling and storage facility? Has Dow agreed to deliver to your facility? Note: Dow will not deliver to a facility without performing an on-site review to verify that it meets our required practices for bulk delivery.
• Have you arranged for a Dow

Product Steward to attend the first delivery? • Was the off-loading piping and

valve system pressure-tested to ensure that it is leak-free? If water was used for the pressure test, howwas the system dried? Was the offloading pump tested with liquid after installation? Note: Any water in the system will create quality and safety problems.
• Is a written off-loading procedure

available to employees? • Was the procedure reviewed by the

off-loading operator? Will theoperator use it as a checklist for offloading? • How will the vehicle be managed

for spill containment? Are there valve position changes required to secure the containment system? Ifso, are they described in the offloading procedure?Note: Dow suggests a spillcontainment volume great enough to hold the entire contents of the vehicle scheduled for off-loading. • Are spotting, chocking, and brake securement requirements clearly identified? Note: For trucks, the driver should have clear instructions to surrender the keys and leave the truck cab.
• Is the operator required to use all of

the appropriate protective gear (e.g., impervious suit, impervious rubber footwear and gloves, hardhat, approved respirator) before offloading? • Are the safety shower and eye wash

stations immediately accessible in the off-loading area? Are they tested before any connections are made to the vehicle? • Is the off-loading area cordoned off

or barricaded to keep unauthorized personnel and vehicles out? Note: Are warning signs typically used for the mode of transport used to secure the unloading area
• Has the vehicle’s electrical ground

been verified? • Has the off-loading operator

received training on the hazards of the product and reviewed current MSDS/SDS? • Has the driver received appropriate

training and instructions on the specific handling by the customer, if the driver is supposed to assist during offloading? Dow can assist to help manage the training with the carrier personnel. • Will a check be made of the

vehicle’s number, seals, and productidentification tag (on the offloading line) to verify the product against both the delivery note and Certificate of Analysis? Note: Product stencils / label and accompanying documents on rail cars also should be checked. • Will a sample be drawn and analyzed prior to off-loading? Note: Dow suggests sampling and testing to positively confirm theproduct in the vehicle as epichlorohydrin (see “Sampling of Delivery Vehicles,” page 19).
• What precautions will be taken to

avoid personnel exposure? Is personnel protective equipment adequate? • Are all lines and vessels properly

labeled and identified? • If connections have to be made on

the top of the transport vehicle, is protection against falls adequate? • Was the oxygen level in the storage

tank checked and verified to be below 8 percent? • Are all terminal lines plugged

(blinded) to prevent spills from an accidental valve opening (e.g., sampling and blow-down lines)? • Are a fire extinguisher and suitable

absorbent material available in the immediate area? • Is there a communication link to the

control room? How will it be maintained during off-loading? • Have calculations been made and

confirmed to ensure that the load will fit into the available tank space? • How will the transfer of the load

into the tank be monitored to verify movement of product when the pump is started and to ensure that the product is going to the correct location? How will the movement of vapors through the vapor return line to the vehicle be established and verified? Delivery Procedures30 Note: Truck trailers and Intermodal containers are particularly susceptible to damage from negative pressure and will collapse if not vented. The vehicle safety system may provide an audible warning alarm as it starts to relieve and suck air into the trailer. At any sign of safety valve relief, the transfer should be stopped immediately.
• Is the off-loading procedure clear

about the location and size of the liquid and vapor lines? • When the dry disconnects are

connected, are they locked in place by securing the arms in a closed position? • Before opening the valves on both

the vent and liquid sides, will a careful check for leaks be made? • Are gas detectors installed at

strategic points to sound an alarm if a leak occurs? • At what pressure is the storage

tank? Note: If it is at a pressure that exceeds the vehicle safety system, the pressure relief valve will open and a vapor cloud will be released. Pressure relief valves in North America are typically set to 25 psig (trailers), and 75 psig (rail cars). In Europe, the safety pressure setting is 400 kPa (4 bar) with initial opening at 300 kPa (3 bar) for both rail cars and Intermodal containers.
• After the transfer is initiated, is the

operator required to stay within sight of the connections until the load is completely transferred? If a rail car is involved, how will it be monitored? Note: This is required by U.S. law for tank trucks and rail cars. • How will the operator know when the vehicle is empty so that the pump can be shut down as soon as it loses suction? • If the liquid line will be blown clear

prior to disconnection, how will the nitrogen be regulated to not exceed the pressure at which the vehicle’s safety system begins to relieve? Are steps defined and followed if a blow-down is performed? Note: Hoses should not be left hydraulically full.
• What procedure will be used to

ensure all liquid and vapor return lines on the car and piping systemare correctly blown clear, depressured, and blocked to secure the system and the delivery vehicle? Note: Specially trained and licensed workers are required to accomplish the task of rail car and truck

securement. • When disconnection of the dry

break fitting occurs, does the procedure require the use of appropriate protective gear? • Will the hoses be secured to keep

them clean and contamination-free for the next load? • Will the operator ensure that the fall restraint, chocks, ground strap, and barricades are removed and that the placards are reversed and derail and warning signs are removed before releasing a rail car? • Rail cars and European Intermodal

containers also have top discharge lines. Establishing pump suction requires specific operating procedures. How will this be managed? Note: The procedures must either utilize the pressure in the car upon arrival (North America 5 to 9 psi). In Europe, the overpressure in the cars and containers on the shipping point will be approximately 30 kPa (0.3 bar). Alternatively, the pressure can be provided by an inert gas (nitrogen) through the gas phase connection of the delivery vehicle to push the product out of the car to flood the pump suction.

Note: The customer should have a check valve in the inert gas line to avoid contamination and back flow into the inert gas system.
• What mechanism is in place that

allows the operator to factor any learning experiences into the nextoff-loading experience - to continuously improve performance? Delivery Procedures31 

# Storage and Equipment 

# T he guidelines in this section of the Epichlorohydrin Product Stewardship Manual are general and should be used with information from tank and equipment manufacturers and professional engineering firms. Dow Product Stewards can help you evaluate engineering suggestions and can assist you with ecological and product safety considerations. Dow can provide technical assistance during equipment installation, review your site prior to the first delivery, and assist your staff during that delivery to ensure that minimum requirements are met for a safe, exposure-free delivery. We can also review customer-supplied schematics of storage and off-loading equipment, and make suggestions for improvement. Contact your Dow representative for information, or call the Dow location nearest you.


## Materials of Construction Carbon steel is satisfactory for the transport and storage of epichlorohydrin. Steel is used for storage tanks, lines, valves, and fittings, and tank cars. Tank trucks are usually of stainless steel construction. If the material will be stored longer than 12 months, color may develop. In such cases, stainless steel tank construction should be considered. Cast iron is not recommended for auxiliary equipment, such as pumps and valves, due to its brittleness.



### Hazardous Materials Warning: The following materials can create varying degrees of hazard due to their incompatibility with epichlorohydrin. 

### Aluminum, Magnesium, Copper, Tin, Zinc, Lead, and Their Alloys These metals should not be used in systems containing epichlorohydrin because of their potential to initiate a violent polymerization reaction. Similarly, alloys of these metals (such as bronzes and some brass compositions) should be avoided. 

### Catalysts Epichlorohydrin may polymerize spontaneously and with explosive violence in the presence of catalysts such as acids, bases, and compounds having labile hydrogens (Lewis acids). Back-flow into storage vessels or lines must be prevented.

DOW TM Epichlorohydrin

TM Trademark of The Dow Chemical Company (“Dow”) or an affiliated company of Dow32 

## Bulk Handling Checklist Some specific engineering design andprocedural/operational considerations for off-loading and storage systems include: • Spill containment for the storage

tank and for vehicles that will be off-loaded. Note: A volume sufficient to hold the entire contents of the tank and vehicle is suggested.
• A nitrogen pad on the storage tank

to ensure that the tank contents remain at less than 8 percent
oxygen. • Isolation of the epichlorohydrin

storage tank from storage areas containing materials reactive with epichlorohydrin. • Fire protection meeting local

standards. • Over-pressure of the storage tank

under normal and worst case conditions (usually fire). • Overfill of the storage tank (e.g.

level measurement, alarms and shut-down of unloading pump). • Temperature measurement on the

tank and pump. • Oxygen measurement, particularly

with a new facility prior to first delivery. • Pump shut-down under abnormal

conditions (e.g. deadhead, tank high level, low flow, high pump temperature, and lack of flow in vent back to vehicle). • Exposure of workers and the

environment during connection of the transfer. Note: Dow suggests using dedicated equipment permanently attached to transfer piping. Storage and Equipment

• Fittings to match those on the delivery vehicle. • Use of a customer-supplied pump

with a closed-loop vapor return line. This is suggested over the use of nitrogen to pressure off the product with vapor abatement on the storage tank. • If a closed-loop vapor return is not

used, make sure that sufficient nitrogen is available and utilized to ensure that the oxygen level in the vehicle being off-loaded is permanently maintained at less than 8 percent. Note: Consider the allowed maximum pressure of the delivery vehicle. Dow prefers that delivery vehicles are returned with an overpressure of not more than 100 kPa (1.0 bar, ~15 psig)
• A sampling system and testing

mechanism to confirm the product in the vehicle as epichlorohydrin (see Handling and Sampling Guidelines in “Health, Safety, and Handling,” page 12). • Blow-down of the unloading line

prior to its disconnection from the delivery vehicle. Note: It is suggested that nitrogen be regulated to less than 100 kPa (1.0 bar, ~15 psig). • Prevention of back flow of any streams into the storage tank. • Plugging of line ends to prevent

spills from an accidental valveopening (e.g. sampling and blowdown lines). • Electrical grounding for storage

tank, delivery vehicle, and offloading system. • Safety shower and eye bath

immediately accessible to the offloading area, and tested prior to beginning the transfer. • Waste disposal practices to meet all

regulations. • Tank and line labeling to indicate

epichlorohydrin. Note: The use of NFPA symbols (Health=3, Flammability=3, Reactivity=2) on the tank are suggested in North America.
• Flammable gas detection around

the tank and other potential spill

areas. • Process hazard analysis (see also

“Emergency Preparedness,” page 21). • Emergency preparedness. Note: It is suggested that a Plant Emergency Plan be coordinated with the overall community emergency plan (see “Emergency Preparedness,” page 21).
Also refer to Figures 11 and 12 for schematics of a typical bulk storage and tank truck off-loading system, and a typical rail car off-loading system.33 

### Figure 11: Typical Bulk Storage and Tank Truck Bottom Off-Loading System for Epichlorohydrin

1. Pump to be turned off by:

- High level in tank - Low pump discharge flow - High temperature - Low vent flow - Low pump discharge level - Loss of electrical ground 2. Safety shower must be quickly accessible from all product handling areas. 3. For top off-loading configuration see rail car schematic, Figure 11 4. Vapor and liquid lines 2-inch and 3-inch respectively in Europe 5. See notes on page 19, Sampling of Delivery Vehicles.

Legend PCV = Pressure Control Valve HLA = High Level Alarm TT = Temperature Transmitter PI = Pressure Indicator ERV = Emergency Relief Valve LI = Level Indicator EBV = Emergency Block Valve PT = Pressure Transmitter
VRV = Vacuum Relief Valve LT = Level Transmitter FI = Flow Indicator GAS DET = Flammable Gas Detector HLS = High Level Switch TI = Temperature Indicator FT = Flow Transmitter

This schematic drawing is provided in good faith by Dow. However, as the delivery, storage, use and disposal conditions are no t within its control, Dow does not guarantee results from the use of the schematic. The customer is advised to employ a qualified engineeri ng service to design and build their storage and handling facility. Since any assistance furnished by Dow with reference to the safe delivery, storage, use and disposal of its products is provided without charge, Dow assumes no obligation or liability. Storage and Equipment

1

1

1 1 1 1 1

4 4

3
2

5 Note: Label Lines for Content

Tank Truck Deluge/Foam

To Process

Low Point Drain Centrfugal Pump Ground Slope Spill Containment Wall Epichlorohydrin Access Platform Depad to Vent Scubber

Flex Hose Valve or Vapor Line

Dry Disconnect

Fittings To Sample System Safety shower & Eyewash
To Deluge System

Vent to Safe Area

Foam Stor. Fire Monitor Fire Ext. Nitrogen Nitrogen PCV

PCV

EBV PCV ERV ERV

VRV

HLA

FI FT LI 3 3 2 LT

PI PT PI PT FI FT

FI FT

GAS DET. HLS HLA

TI TT

TI TT Vehicle Spill Containment (Remote)1 1/2" Vapor

2" Liquid

Ground Absorbent34 

### Figure 12: Typical Rail Car Top Off-Loading System for Epichlorohydrin Storage and Equipment

2

Epichlorohydrin Rail Car

Locate Derail at Least 50' Before Rail Car Vent to Safe Area

Ground (Optional Interlock with Off-loading Pump) Spill Containment (Remote) 1 4 3

To Sampling System To Storage Tank

1-1/2" Vapor

3 2" Liquid

Safety Shower

& Eyewash

PI PCV

Customer Access Platform

Plan View of Rail Car Dome Liquid Discharge

Vent

Spl. Valve 1 Nitrogen

1. Temporary handrail to be installed when working on the top of rail car. 2. Additional safety shower required at ground level to be quickly accessible from all product handling areas. 3. Vapor and liquid lines are 2-inch and 3-inch respectively in Europe. 4. See notes on page 19, Sampling of Delivery Vehicles.

Legend

PCV= Pressure Control Valve PI= Pressure Indicator

This schematic drawing is provided in good faith by Dow. However, as the delivery, storage, use and disposal conditions are no t within its control, Dow does not guarantee results from the use of the schematic. The customer is advised to employ a qualified engineeri ng service to design and build their storage and handling facility. Since any assistance furnished by Dow with reference to the safe deli very, storage, use and disposal of its products is provided without charge, Dow assumes no obligation or liability.35 

### Figure 13: Unloading a Bulk Tank Truck A Dow customer demonstrates a typical hook-up of a bulk tank truck with dry disconnects Storage and Equipment



### Figure 14: Typical Intermodal ISO Container

Photo courtesy of HOYER GmbH Hamburg, Germany, www.hoyer-group.com36 

## Tank Storage The suggested storage tank for epichlorohydrin is an American Petroleum Industry (API) Type 620 tank that uses a nitrogen pad of 40- 70 kPa (6-10 psi, 0.4-0.7 bar). American Society of Mechanical Engineers (ASME) code vessels with higher pressure ratings are also excellent choices. A European design standard for tanks and vessels is EN 14015. Note: The vapor pressure of epichlorohydrin is low enough that an atmospheric pressure tank (such as API Type 650 tank) could be used, but would probably not be the best choice due to the difficulty in maintaining a positive nitrogen pressure on the tank without venting epichlorohydrin vapors. Such a system would require special considerations to ensure that the vapors are appropriately scrubbed and did not pose an exposure potential for workers.
In any case, the tank should be designed, constructed, installed, and used in accordance with the appropriate national codes for epichlorohydrin storage. National Fire Protection Association (NFPA) codes are appropriate for North America. The tank should also meet all local codes and ordinances. Carbon steel tanks are normallysuitable for storage of epichlorohydrin. If the material will be stored for more than 12 months, however, stainless steel construction should be considered to prevent discoloration. Storage tanks must be constructed to relieve excessive pressure in case of fire. This can be achieved through pressure relief valves or emergency relief vents of adequate capacity to relieve tank over-pressure and to prevent rupture. Note: Open vents should not be used to avoid emissions to the atmosphere due to breathing of the tank.
Storage tanks must be diked or otherwise contained. Positive drainage to an impounding area that avoids exposure to personnel orequipment is suggested. Shell-toshell separations of tanks should be based on loss prevention principles. The minimum distance from the tank shell to the dike wall should be set to prevent trajectories of escaping liquid (from possible leaks) from clearing the dike. Dikes should be designed with adequate volume to hold the maximum foreseeable spill with additional volume to contain deluge water and foam from extinguishing systems. Management of water during an emergency situation must be incorporated in the design. Note: Careful design by a qualified engineering service is required to ensure an appropriately sized containment design to manage all potential emergencies.
Water spray rings around the tank are suggested to provide a water deluge when fighting fire (it also provides additional cooling for the tank in a fire situation). These same spray rings can be used to deliver foam by injecting the foaming agent into the water supply. Fire-fighting monitors around the storage facility should be considered as part of the design. Again, the fire protection system must be carefully designed by engineering experts who specialize in this service. The storage tank should be equipped with a nitrogen gas padding system. An effective gas padding system can be created using a pressure control valve on the nitrogen supply line to maintain a minimum pressure (pad). It can also feature a maximum pressure (de-pad) pressure relief valve on top of the storage tank to prevent over-pressure. Such a system will not only provide a minimum positive pressure and protect against excessive pressure build-up, but also will conserve nitrogen. The nitrogen pad will preclude air from entering the system. Air contains moisture that can react with epichlorohydrin and/or its impurities to form other compounds which can be reactive or catalytic in nature.
Note: Tank vents should be handled in a manner that prevents personnel exposure and is acceptable from an emissions standpoint.
Dow suggests that vented material be handled by vapor return to the delivery vehicle. Tank breathing vapors are preferably incinerated in a well-designed incineration unit. Alternatively, the breathing vapors can be absorbed with a caustic scrubber, an absorption unit, or by condensation. Any of these systems will require a careful design by a qualified engineering service. Mechanical pressure vacuum relief devices should also be provided to satisfy the relief requirements of codes and standards applicable to installation (e.g., NFPA in North America, EN standards in Europe). Additional equipment should include adequate manholes or entrance passages that allow workers to clean or repair tanks, a bottom drain to completely empty tanks when necessary, and two independent level measurement devices. Storage and Equipment37 Also, be sure that the tank and all metal piping and pumps are electrically grounded. See Figures 11 and 12 for further instrumentation and control suggestions. Because epichlorohydrin may homopolymerize spontaneously and with explosive force (100 kJ/mol, 24.3 kcal/mol at 25 ̊C/77 ̊F) in the presence of catalysts such as acids, bases, and compounds having labile hydrogens, it should be stored only in tanks that have been thoroughly cleaned and dried, e.g., buffed and steamed, water-washed, and dried with an inert gas, such as nitrogen (See section Tank Cleaning Procedures). Note: Combining epichlorohydrin and water can form a particularly hazardous two-phase mixture (see “Properties and Uses,” page 6, for solubility information). Over time, an exothermic reaction will start at the interface which can generateenough heat to create pressure buildup in the vessel. Such mixtures must be disposed of promptly (see “Emergency Preparedness,” page 21, for disposal information).
Great care must be taken to prevent back flow or other inadvertent addition of reactive materials to the storage tanks. Prior to start-up, a process hazards analysis should be performed to identify flow, temperature, pressure, equipment failure, operating errors, or other conditions that could create an unexpected hazard (see “Emergency Preparedness,” page 21). 

## Tank Cleaning Procedures The following procedure to clean tanks containing epichlorohydrin is suggested. Note: Tank cleaning will requirepersonnel to enter the epichlorohydrin storage vessel. To ensure this is done safely, a detailed vessel entry procedure that includes the testing of the environment in the tank should be developed by qualified personnel. The procedure should be used and signed by the responsible people, including the operator and trades
person. 1. Use a pump to remove the epichlorohydrin from the tank until the pump loses prime. 2. Blind or remove all process piping from the tank to avoid accidental flows into the tank during the clean-up or tank entry procedures. 3. Fill the tank at least half way with water to remove any liquid pockets of epichlorohydrin. If the tank is too large or disposal of water is a problem, this step may be omitted if the following Step 4 is performed. 4. Water-wash for at least 8 hoursusing some form of multidirectional spray washing nozzle (e.g., the type used to wash tank trucks or cars). Alternatively a 10 percent Sodium hydroxide solution can be used for about 1 hour. Note: This step is essential to tank cleaning; it greatly minimizes the amount of epichlorohydrin that could vent out in the following steps. 5. The remaining steps of the cleaning procedure are dependent upon the type of lining and exterior paint on the tank, and the amount of deposits in the tank itself. These steps are categorized as low-, medium-, and high-temperature cleaning procedures. Follow Steps 1-4 above, then proceed with the steps described in the low-, medium-, or high-temperature categories. Note: It is very important to use the following cleaning procedures regarding proper temperature limits on linings, exterior paints, and insulation, since most manufacturerís guidelines do not have large safety factors. Linings and exterior paints are very easily damaged by heat, and are expensive to repair.
Note: All water and epichlorohydrin mixtures must be contained and disposed of as required by regulations (see “Waste Disposal,” page 25).



### Low-Temperature Cleaning This type of procedure should be used for any tank that is lined, insulated, or painted with a material that is not capable of withstanding above-ambient temperatures. 5a. Continue washing with themultidirectional spray nozzle setup for an additional 12-16 hours. Open all drains on the tank. 5b. Connect an air-moving device capable of quickly turning over the air volume in the tank. 5c. Test the tank environment for flammability, toxicity, and oxygen content. See under tank entry below. 5d. If the air test results show that it is not acceptable to enter, continue to wash the tank until acceptable limits are reached. Storage and Equipment38 

### Medium-Temperature Cleaning This type of procedure is appropriate for tanks that are lined, insulated, or painted with a material capable of withstanding boiling water up to 100 ̊C (212 ̊F), but not direct steaming. 5a. Open a vent valve at the top of the tank and fill the tank 80 percent with water. 5b. Connect a steam hose to the bottom of the tank and introduce steam. Raise the water temperature to boiling, then boil the water for 6 to 8 hours. Be careful not to overboil, causing water to exit the vent valve. 5c. Drain the water and purge the tank to ambient temperature with an air-moving device. 5d. Test the tank environment for safe levels of flammability, toxicity, and oxygen. See under tank entry below. 5e. Repeat the boiling procedure if the air tests are unacceptable. Continue until acceptable limits are reached.


### High-Temperature Cleaning Use this procedure for any tank that is lined, insulated, or painted with a material capable of withstanding temperatures up to 250 ̊C (482 ̊F). 5a. Open the vent and drain valves on the tank. 5b. Connect a low pressure (240 kPa, 2.4 bar, ~35 psig or less) steam hose to the tank and flow steam into it, making sure that the tank does not over-pressure. 5c. Increase the tank temperature to 95 ̊C (203 ̊F) for 2 to 4 hours, oruntil no detectable epichlorohydrin is remaining. 5d. Turn off the steam, connect an air-moving device, and cool the tank down to ambient temperature. 5e. Test the tank environment for acceptable levels of flammability, toxicity, and oxygen content as outlined in the tank entry section below. 5f. If any tests show that it is unacceptable to enter, the tank should be further steamed until acceptable limits are reached.


### Tank/Vessel Entry A written tank entry procedure should be in place. This procedure should regulate which tests have to be done prior to the approval of tank entry by a responsible person. Required tests are oxygen content, flammability, detectable epichlorohydrin and electrical safety. Suggested additional tests are temperature (especially after steaming). The procedure should further regulate who gives the final approval for tank entry. Persons entering tanks should wear appropriate personal protective gear.


### Table 11: Guidelines for Acceptable Tank Entry

Conditions Acceptable Levels Flammability Essentially zero Toxicity Less than 0.5 ppm epichlorohydrin in vapor space Oxygen content 19.5-23.5 percent Temperature Less than 40  ̊ C (104  ̊ F) Note: If the tank contained other compounds, the environment should be tested for safe levels of those compounds, too. Check with the relevant manufacturer for acceptable levels of entry.



### Recommissioning Before filling a tank with epichlorohydrin, follow these steps: 1. Pad and de-pad with nitrogen until the measured oxygen content is 8 percent or less. 2. The tank must be dry. This can be assured by making a dew point determination on a representative sample of a nitrogen purge flow fromthe tank. A dew point of less than -40 ̊C (-40 ̊F), as measured by a dewpoint apparatus, is used at Dow as the acceptable level of dryness. 3. Ensure that all safety and other systems are reinstalled and tested to verify correct operation.
Note: Nitrogen Hazard! A number of fatalities have recently been caused by persons entering into areas and equipment with oxygen-deficient atmosphere. If a person enters an atmosphere of nitrogen, he or she can lose consciousness without any warning symptoms in as little as 20 seconds. Death can follow in 3-4 minutes. A person falls as if struck by a blow on the head. All personnel should know that one deep breath of 100 percent nitrogen will be fatal. Breathing is stimulated and controlled (cerebellum) by carbon dioxide present in the lungs. 100 percent nitrogen will displace carbon dioxide completely. In the absence of a carbon dioxide signal to the brain, breathing stops. Personnel should not work in or enter atmospheres with oxygen concentration below 19.5 percent or above 23.5 percent, unless equipped with a self-contained breathing apparatus or breathing air mask. This is also true of rescue personnel who can be overcome by the same oxygen-deficient atmosphere as the initial victim. Storage and Equipment39 

## Equipment Specifications Examples below may be specific to North America. Check with your country standards or involve a local engineering company. Lines, valves, pumps, and fittings can be of ordinary carbon steel or ductile iron.
Note: Do not use cast iron due to its brittleness. Also avoid aluminum, magnesium, copper, tin, zinc, lead, and their alloys due to their potential reaction with epichlorohydrin.
Spiral-wound gaskets with polytetrafluoroethylene (PTFE) filler, flexible graphite filler, or filled PTFE gasket (e.g. Gylon 3510 or Durlon 9000) have been used satisfactorily. Centrifugal pumps equipped withdual mechanical seals or magneticallydriven (seal-less) generally provide good protection for workers. When mechanically sealed pumps areused a combustible gas detector (exdetector) is recommended. The gas detector should be located near each epichlorohydrin pump to detect any pump seal leaks. The number of flanged connections should be kept at a minimum to minimize fugitive emissions. Exterior painting is also suggested. Threaded connections should be kept to an absolute minimum and no steam tracing should be used on piping. Table 10, page 28 provides guidelines for tank piping and other equipment used for epichlorohydrin storage and transfer systems. For specific information about tank hardware, consult with a professional engineering firm and, if desired, discuss engineering specifications with Dow. Talk to your Dow representative or contact your nearest Dow location. 

### Table 12: Equipment Specifications Dow suggests stainless steel (316 SS) equipment be used to store and handle epichlorohydrin. Carbon steel is also a suitable construction material. Gaskets Spiral-wound, 304 stainless steel or Monel winding, PTFE or flexible graphite filler, 0.175" thick, API-601 for ASME/ANSI B16.5 flanges, carbon steel centering ring, no inner ring. Flat ring: filled PTFE, 1/16" thick, Gylon 3510, Blueguard 3700 or Durlon 9000. Dry Break Valves e.g Civacon for the 1 1/2" and 2" female couplers and male adapters respectively. Note: dry-break couplings are currenly used only in North America.

“ O ” Rings PTFE, EPDM, EPR, Viton, Kalrez 4079.

“ V ” Rings PTFE Pumps Seal-less pump, preferably magnetic drive used in clean service. Mechanical seal pumps (centrifugal), double seal using non-toxic
purge. Pump body duplex stainless steel; CD4M (cast) or 2200 series (plate) steel, ductile iron or 316 stainless steel. Volute case gasket, glass-filled PTFE or PTFE envelope. Seal Hard Faces Carbon/tungsten Hoses Polypropylene lined with inner wire construction 316 SS. (e.g. Wilcox type 4091 or equivalent). Polypropylene with PVC linings and galvanized outer wire (e.g. Chemoflex 0416-PG). Tank Linings Unlined steel acceptable for most applications. Contact your Dow representative for linings information. Electrical Minimum-U.S. Class I, Division II, Group C. Classification Maximum-Class I, Division I, Group C. Electrical motors should have individual high temperature protection. All equipment should be grounded.
Note: The customer is advised to employ a qualified engineering service to design and build its storage and handling facility. Since any assistance furnished by Dow with reference to the safe delivery, storage, use and disposal of its products, is provided without charge, Dow assumes no obligation or liability. Storage and Equipment40 

# P lease consult your Dow representative for analytical methods for testingthe quality of epichlorohydrin, analyzing trace amounts of epichlorohydrin in water, and monitoring epichlorohydrin (and diglycidyl ether) in air. The Dow assay method for epichlorohydrin is applicable to epichlorohydrin having 99.0 percent or greater purity. Impurities are determined and the sum of those concentrations is subtracted from 100 percent. The complete Dow analytical method (method ID: DOWM 100408) is available on request. Note: Prior to conducting any tests on epichlorohydrin, however, see “Health, Safety, and Handling” on page 12.



### Other safety considerations include: • Use of appropriate respiratory, hand, body, and eye protection should be

determined according to the exposure potential of each operation. • Carbon disulfide and other reagents may pose health hazards. Follow the

safety precautions suggested by the reagent supplier. • Each analyst should be acquainted with the potential hazards of the

reagents, products, and solvents before commencing laboratory work. Sources of information include: MSDS/SDS, technical and product literature, and other related data. Safety information on non-Dow products should be requested from the relevant supplier. Disposal of reagents, reactants, and solvents must be in compliance with applicable government requirements within your country.



### Other Useful Methods The following sources are useful methods for testing epichlorohydrin. They are available from the ASTM International, 1916 Race Street, Philadelphia, Pennsylvania 19103, U.S.A. • “Water in Liquid Petroleum Products by Karl Fischer Reagent,” Designation

ASTM E-203.• “Color of Halogenated Organic Solvents and Their Admixtures (PlatinumCobalt Scale),” Designation ASTM D-1209. 

# Analytical Methods

DOW TM Epichlorohydrin

TM Trademark of The Dow Chemical Company (“Dow”) or an affiliated company of Dow41 

# D etails to the country-specific regulatory requirements are provided in section 15 of the country-specific MSDS/SDS. Dow recommends you review the MSDS/SDS prior to any work. 

## Chemical Inventory Listing Epichlorohydrin (CAS Number 106-89-9) is listed in the following national chemical inventories:



### National Chemical Chemical Substance Inventory number Inventory Inventory
Australia AICS 106-89-8
Canada DSL 683
China SEPA 106-89-8 European Community EINECS / ELINCS 2034398 67/548/EEC Annex I 603-026-00-6
India List of Hazardous Chemicals 106-89-8 Japan ENCS / ISHL (2)-275
Korea KECI KE-05647 New Zealand Composite list of Single 106-89-8 Component Substance to be considered for transfer (April 2003) Philippines PICCS 106-89-8
Switzerland Giftliste 1 G-1614
USA TSCA 106-89-8 

# Regulatory Requirements

DOW TM Epichlorohydrin Legend - AICS = Australian Inventory of Chemical Substances
- DSL = Domestic Substances List - EINECS = European Inventory Existing Commercial Chemical Substances - ELINCS = European List of Notified Chemical Substances - ENCS = Inventory of Existing and New Chemical Substances - ISHL = Industrial Safety & Health Law Inventory - KECI = Korean Existing Chemicals Inventory - PICCS = Philippine Inventory of Chemicals and Chemical Substances - SEPA = State Environmental Protection Agency China Chemical Inventory - TSCA = Toxic Substances Control Act Chemical Substances Inventory

TM Trademark of The Dow Chemical Company (“Dow”) or an affiliated company of Dow42 

## International Transportation Requirements Section 14 of the country-specific MSDS/SDS provides details about the transportation restrictions and labeling requirements. The details provided below reflect the international transportation classification status for the year 2006.



### Road & Rail Proper shipping name EPICHLOROHYDRIN
Truck/Rail ADR/RID 6.1
Label 6.1+3
Classification Code TF1 Packing Group II
Kemler Code 63
UN Number 2023
Tremcard Number CEFIC 61S2023



### Sea Proper shipping name EPICHLOROHYDRIN
Sea - IMO/IMDG Class 6.1
UN Number 2023
Label 6.1+3 Packing Group II

EMS 6.101 Marine Pollutant (Y/N) Y



### Air Proper shipping name EPICHLOROHYDRIN
Air-ICAO/IATA Class 6.1
UN Number 2023
Label TOX+FL
Sub Class 3 Packing Group II Pack Instruction (Passenger) 609 Pack Instruction (Cargo) 611

Remarks: Sample shipment not allowed by mail. Regulatory Requirements43 

# I f you would like additional information about DOW TMEpichlorohydrin, or if you have questions about any of the topics discussed in this manual, please contact your Dow representative or call one of the following numbers for your North American, European, Asia Pacific or Latin American location.


## North America

Plastics Products Information Customer Information Group +1 800 441-4369 (toll free in U.S.A.) from 8 a.m. to 5 p.m. Eastern Time or +1 (989) 832-1426 from 8 a.m. to 5 p.m. Eastern Time


### Emergency Response (U.S.A.) The Dow Chemical Company Distribution Emergency/Response Center +1 800 DOW-CHEM (24 hours toll free in U.S.A.) or +1 800 369-2436 (24 hours toll free in U.S.A.) or +1 (979) 238-2112 (24 hours) Emergency Medical Information +1 (989) 636-4400 CHEMTREC +1 800 424-9300 (toll free)


### Emergency Response (Canada) Fort Saskatchewan, Alberta +1 (780) 998-8282 (24 hours) Sarnia, Ontario +1 (519) 339-3711 (24 hours) Verennes, Quebec +1 (450) 652-1010 CANUTEC +1 (613) 996-6666 

# Appendix

DOW TM Epichlorohydrin

TM Trademark of The Dow Chemical Company (“Dow”) or an affiliated company of Dow44 Appendix 

## Europe, India, Middle East and Africa

Plastics Products Information Customer Information Group
+800 3 694 6367#(toll free) from 9 a.m. to 5 p.m. Central European Time +800 783 825 (toll free) Italy 0800 99 5078 (toll free) South Africa +32 3 450 2240 from 9 a.m. to 5 p.m. Central European Time +32 3 450 2815 (24 hours fax)

#International toll free call from Austria , Belgium, Denmark, Finland (prefix 990), France, Germany, Hungary, Ireland, The Netherlands, Norway, Portugal, Spain, Sweden, Switzerland, and the United Kingdom.


### Emergency Response Terneuzen, Netherlands +31 115 69 4982 Emergency Medical Information +31 115 69 4982 

### Benelux: Belgium/Netherlands Terneuzen, Netherlands +31 115 69 4982 

### Eastern Europe/Israel/Middle East/Africa Terneuzen, Netherlands +31 115 69 4982



### Finland Hamina, Finland +358 5 730 2400



### France Drusenheim, France +33 388 53 3676


### Germany Stade, Germany +49 4146 91 2333 Product Safety Information, Rheinmuenster, Germany +49 7227 91 2200



### Greece Lavrion, Greece +30 2920 62297 

### Iberia: Spain/Portugal Tarragona, Spain +34 977 54 3620



### India Mumbai, India +91 22 6797 8600 

### Italy Livorno/Priolo, Italy +39 335 697 9115 

### Scandinavia: Sweden/Norway/Denmark Norrkoeping, Sweden +46 8 640 9011



### Switzerland/Austria Product Safety Information, Rheinmuenster, Germany +49 7227 91 2200 

### Turkey Dilovasi, Turkey +90 262 754 5174 

### United Kingdom/Eire Kings Lynn, United Kingdom +44 1553 76 125145 

## Asia Pacific

Customer Information Group

+800 7776 7776 #(toll free)

+60 3 7958 3392

#except Indonesia and Vietnam


### Emergency Response

Australia 1800 033 882 (toll free)



### China
+86 532 8388 9090


### Hong Kong +852 2431 3300



### Indonesia
+62 254 57 1369


### Japan Emergency Response +81 120 00 1017 Product Safety Information +81 3 5460 2100



### Korea +82 2 551 0601 

### Malaysia 1800 80 1255 (toll free) 

### Philippines
+63 43 485 0411


### Singapore 1800 332 3543 (toll free), +65 6332 3543



### Taiwan
+886 49 226 0560



### Thailand
+66 3 868 3210



### Vietnam
+84 903 99 6653 Appendix46 

## Latin America

Customer Information Group +55 (11) 5188 9222


### Emergency Response
Argentina +54 (3476) 43 8600 or +54 (291) 459 1400 or +54 (291) 459 1563



### Brazil Guaruja +55 (13) 3358 8226
Bahia +55 0800 282 5015



### Chile +56 (41) 50 8300



### Colombia +57 (5) 668 8000



### Costa Rica +57 (5) 668 8000 or +52 (241) 412 7143



### Ecuador +57 (5) 668 8000



### Mexico +52 (241) 412 7143 or +1 800 369 0000 (toll free) Dow U.S.A. Emergency 1 (979) 238-2112 or 1 880 369-2436



### Peru +57 (5) 668 8000 or +51 (1) 264 0012



### Puerto Rico +57 (5) 668 8000 or +52 (241) 412 7143



### Venezuela +57 (5) 668 8000

Alternatively, visit our web site at www.dowepoxy.com Appendix47 

### Contact Information:
North America: +1 800 441-4369 +1 (989) 832-1426 +1 (989) 832-1465 (fax)

Mexico: +1 800 441-4369 Brazil: +55 (11) 5188 9222 +55 (11) 5188 9749 (fax) Europe: +800 3 694 6367

+32 3 450 2240 +32 3 450 2815 (fax)
Asia Pacific: +800 7776 7776 #

+800 7776 7779 #(fax)

+60 3 7958 3392 +60 3 7958 5598 (fax)

#Except Indonesia and Vietnam http://www.dowepoxy.com

Notice: No freedom from any patent owned by Dow or others is to be inferred. Dow assumes no obligation or liability for the in formation in this document. The information provided herein is presented in good faith and is based on the best of Dow’s knowledge, information, and belief. S ince use conditions at non-Dow facilities are beyond Dow’s control and government requirements may differ from one location to another and may change with tim e, it is solely the Buyer’s responsibility to determine whether Dow’s products are appropriate for the Buyer’s use, and to assure the Buyer’s workplace, use, and disposal practices are in compliance with applicable government requirements. Consequently, Dow assumes no obligation or liability for use of these mate rials and makes no warranty, express or implied. The user of the information provided is solely responsible for compliance with any applicable government re quirements. NO WARRANTIES ARE GIVEN; ALL IMPLIED WARRANTIES OF MERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE ARE EXPRESSLY EXCLUDED. Dow does not endorse any third party products referenced in this document. References to “Dow” or the “Company” mean The Dow Chemical Company and its consolidated subsidiaries unless otherwise expresslynoted.

®Trademark of The Dow Chemical Company (“Dow”) or an affiliated company of Dow Form No. 296-01301-0507X SD Published May 2007