Product Stewardship Manual

Safe Handling and Storage

DOWTM Epichlorohydrin
2

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

DOWTM 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 Dow
3

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

DOWTM 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 Dow
4

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.

Introduction
5

This 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)

DOWTM 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/ft3 73.3

Dielectric Constant, at 20 ̊C 23

Empirical Formula C3 H5 OCl

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)

H2C––CH––CH2CI

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 Dow
7

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 nD

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 Uses
8

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 CH2––CH––CH2CI + ROH

O

catalyst R––O––CH2

––CHOH––CH2CI

CH2––CH––CH2CI + ROH + NaOH

O

H2O R––O––CH2

––CH––CH2 + NaCI + H2O

O

Organic Acids

and Salts

CH2––CH––CH2CI + RCOOH

O

RCOO––CH2––CHOH––CH2CI

HO––CH2––CHOOCR––CH2CI

+

CH2––CH––CH2CI + RCOONa

O

ROOCH2––CH––CH2 + NaCI

O

CH2––CH––CH2CI + (RCO)2O

O

RCOOCH2 Anhydrides ––CH(OOCR)––CH2CI

CH2

––CH––CH2CI + RCOCI

O

Acyl Chlorides CH2

CI––CH(OOCR)––CH2CI

R H

O O

C

CH2––CH––CH2CI + RCHO CICH2 Aldehydes ––CH––CH2

O

R R1

O O

C

CH2––CH––CH2CI + RCOR1 CICH2 Ketones ––CH––CH2

O

CH2––CH––CH2CI + RHNH RHNCH2 Amines ––CHOH––CH2CI

O

CH2 Grignard Reagents ––CH––CH2CI + RMgBr CH2R––CHOMgBr––CH2CI

O

CCH2R––CHOH––CH2CI CH2OMgBr––CHR––CH2CI

H2O +

CH2

OH––CHR––CH2CI

+

CH2 Water ––CH––CH2

CI + HOH CH2OH––CHOH––CH2CI

O

CH2––CH––CH2CI CH2

OH––CHOH––CH2OH + NaCI

Water and

Sodium Hydroxide

O

CH2 Inorganic Acids ––CH––CH2CI + HCI CH2CI––CHOH––CH2CI

and Salts

O

CH2––CH––CH2CI + NaHSO3 CH2CI––CHOH––CH2––SO3Na

O

H2O

CH2––CH––CH2CI + RSH RS––CH2 Organic Sulfur ––CHOH––CH2CI

O

CH2––CH––CH2CI + RSH

O

R––S––CH2––CH––CH2 + NaCI + H2O NaOH

O

Table 3: Typical Reactions of Epichlorohydrin
10

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, and

other 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

CH3 I

CH3 I

H

I

H

I

H

I

I

H

I

H

I

O

H

I

H

I

H

 I

CH3

 I

CH3 n O O
11

Ion Exchange Resins

Epichlorohydrin is used to produce

both anion- and cation-exchange

resins. Water-insoluble anionexchange resins having good stability

are prepared by reacting

epichlorohydrin with

ethylenediamine or a higher

homolog. 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 compounds
12

Health, Safety, and Handling

The 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.

DOWTM Epichlorohydrin

TM Trademark of The Dow Chemical Company (“Dow”) or an affiliated company of Dow
13

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 Handling
14

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 Handling
15

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 be

destroyed 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 2007
17

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 “Odor

Threshold,” 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 Handling
18

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 destroyed to 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 SARANTM Resins 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 substantially

above 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 in

Figure 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 Handling
21

Although 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 Assoçiacão 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 Asociación Nacional de la Industria Quimica AC (ANIQ) www.aniq.org.mx

South Africa Chemical and Allied Industries Association (CAIA) www.caia.co.za

DOWTM 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 Dow
22

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 Chemical

Associations (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 Worldwide

Flammable 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 polypropylene

absorbents 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 are

available, 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 Preparedness
26

This section reviews road shipments and rail shipments, and provides adelivery 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

DOWTM Epichlorohydrin
27

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 m3 volume) 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 Procedures
28Delivery 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.de
29

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, how

was 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 the

operator 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? If

so, 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, hard

hat, 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 product

identification 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 the

product 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 Procedures
30

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 system

are 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 next

off-loading experience - to continuously improve performance?

Delivery Procedures
31

Storage and Equipment

The 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.

DOWTM Epichlorohydrin

TM Trademark of The Dow Chemical Company (“Dow”) or an affiliated company of Dow
32

Bulk Handling Checklist

Some specific engineering design and

procedural/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 valve

opening (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 not within its

control, Dow does not guarantee results from the use of the schematic. The customer is advised to employ a qualified engineering 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 Absorbent
34

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

2" Liquid 3

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 not within its

control, Dow does not guarantee results from the use of the schematic. The customer is advised to employ a qualified engineering 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.
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.com
36

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 normally

suitable 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 or

equipment 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 Equipment
37

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 generate

enough 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 require

personnel 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 hours

using 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 the

multidirectional 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 Equipment
38

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, or

until 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 from

the 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 Equipment
39

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 with

dual mechanical seals or magneticallydriven (seal-less) generally provide

good protection for workers.

When mechanically sealed pumps are

used 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 Equipment
40

Please consult your Dow representative for analytical methods for testing

the 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

DOWTM Epichlorohydrin

TM Trademark of The Dow Chemical Company (“Dow”) or an affiliated company of Dow
41

Details to the country-specific regulatory requirements are provided insection 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

DOWTM 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 Dow
42

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 Requirements
43

I

f you would like additional information about DOWTM Epichlorohydrin, 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

DOWTM Epichlorohydrin

TM Trademark of The Dow Chemical Company (“Dow”) or an affiliated company of Dow
44Appendix

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 1251
45

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

Appendix
46

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

Appendix
47

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 information 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. Since 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 time, 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 materials and makes no warranty,

express or implied. The user of the information provided is solely responsible for compliance with any applicable government requirements. 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 expressly noted.

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