p 1

A S TRUST & HOLDINGS INC.

44-129 MIKIOLA DRIVE, KANEOHE, HI 96744

PHONE: 808 2351890 FAX: 808 2350116 CELL: 808 5614688

EMAIL Richard@astrust.com WEB SITE www.hcr188c.com

 Richard H. Maruya

November 11, 2015

Cindy Newberg

Alternatives and Emissions Reduction Branch

Stratospheric Protection Division

U.S. Environmental Protection Agency

1310 L Street, NW, 10th Floor

Washington, DC 20005

RE: Submission of responses to Agency’s June 3, 2014 letter regarding Incompleteness of SNAP 

Submission on the Proposed Use of HCR188C/R443A for Residential Air Conditioning

Dear Ms. Newberg:

A.S. Trust & Holdings is pleased to provide this reply to your letter of June 3, 2014, received by 

our office on October 16, 2015, that addressed concerns by the U.S. Environmental Protection Agency 

re: our SNAP submission for the use of HCR188C/R443A in Residential Air Conditioning systems.

1. Charge Size. See the chart below, with typical values added for capacity and room size for split-system 

heat pumps, split-system air conditioning systems and portable air conditioning units. We can only 

supply suggested, typical values, since each manufacturer will conduct research and development 

efforts to determine the optimum charge size for a given unit for a given application, that balances such 

factors as material costs, manufacturability, manufacturing costs, product weight, product dimensions, 

energy efficiency and system output. (We used systems operating with R410 as a starting point.) The 

maximum allowable charge size for a given system type will have to be decreed by the EPA, which has 

the authority to list this rule for manufacturers to follow.

HCR188C/R443A 

Application

Typical

Charge Size

(g)

Typical

Capacity

(kW)

Typical

House or Room Size

(ft2)

Split-System Heat

Pump

1,560 ga10.9 kW 40

Split-System AC 1,080 gb7.5 kW 40

Portable AC 340 gc3.4 kW 40

a Consistent with charge test (1400 g) on a heat pump per Attachment F of the February 7, 2014 Whitmyre Research report, 

based on a 36 percent charge. Adjusting this to an optimum value of 40 percent charge, the charge size is 1,560 g.

b Consistent with charge test (907 g) on split-system AC per Attachment F of the February 7, 2014 Whitmyre Research report, 

based on a 34 percent charge. Adjusting this to an optimum value of 40 percent charge, the charge size is 1,080 g.

c In its June 3, 2014 incompleteness letter, EPA incorrectly cites the charge rate as 240 g in the text of their letter.
p 2

Per the EPA’s question, the charge sizes of 1,560 g for a split-system heat pump; 1,080 g for a split 

system air conditioner; and 340 g for a portable room air conditioner are still the intended typical charge 

sizes for these applications of HCR188C/R443A. Please note that a minimum room size of 40 m3, or a 

small room approximately 13 ft x 13 ft with an 8-foot ceiling height, in a small 1,600 ft2house (based on 

survey data from the National Association of Home Builders (NAHB)) was used in the modeling of 

exposures. In other words, a small room in a small house was used in the modeling in order to be 

conservative by minimizing dilution volume. However, the margins of safety from the assessment 

indicate that such air conditioning systems can be safely used in rooms of volume much smaller than 40 

m

3

, still providing plenty of dilution volume. The NAHB survey looked at room size data from houses as 

small as 1,600 sq. ft. to houses as large as 6,000 sq. ft., meaning that most rooms on average are actually 

larger than 40 m3, as shown in a table in the report referenced above.

This room-volume assumption is consistent with the room size of 41 m3 specified by the Agency for 

screening for exposures and risks in its hydrocarbon substitutes rule per the July 9, 2014 Federal 

Register notice (Federal Register 79 (131): 38822). For HCR188C/R443A, it is anticipated that the Agency 

will link the maximum allowable charge size to the size of the room as it has for HCR188C/R441A in the 

hydrocarbon substitutes rule, per the July 9, 2014, Federal Register 79 (131): 38811- 38840.

Most air conditioning manufacturers calculate/estimate British Thermal Unit (BTU) values for their 

systems, where one BTU is approximately the amount of energy needed to raise or lower the 

temperature of one pound of water by one degree Fahrenheit (1 F). (Systems are actually rated in 

BTU/hour or kW, though they are commonly abbreviated to just BTU ratings.) The effectiveness of a 

given air conditioning unit depends on the dimensions of the room, the shape of the room, insulation 

conditions and the absolute value of the desired temperature differential. (A sample on-line calculator is 

available at www.calculator.net/btu-calculator.html.)

What we can offer is a recent industrial example based on use of HCR188C/R441A, which, like 

HCR188C/R443A, is a pure hydrocarbon blend, suitable as a replacement for R290 (propane). Engineers 

at MTL Cool, a Quebec, Canada-based manufacturer of refrigerated point-of-purchase display systems, 

were unable to design a display-cooler unit that used less than 150 g of R290 (as required by the EPA). 

They requested samples of HCR188C/R441A and immediately were able to run the same, unmodified

unit with 149 gm; after additional development work to redesign the compressor, evaporator and 

control systems, they found they could operate the improved unit on 116.2 gm and that it even ran on 

17% less energy.

As explained to Margaret Sheppard in a conference call on November 3, 2015, this type of improvement 

will also occur for equipment that could run on HCR188C/R443A, once the EPA lists a maximum charge 

level. Having a clear value for a starting point will make R&D efforts worth the investment for companies 

that are currently seeking low global warming potential (GWP) hydrocarbon refrigerant options. Just as 

with the example of MTL Cool’s development program, once a given maximum charge size is listed by 

the EPA, engineering teams across the air conditioning industry can work to build the mechanical, 

chemical and control systems that comprise an R443A-cooled unit offering the desired BTU/hour (i.e., 

kilowatt) rating. 
p 3

We suggest that the EPA ask a variety of air conditioning system and subsystem (evaporator, condenser, 

etc.) manufacturers for their opinion on a reasonable maximum charge. An average of those values can 

then be listed on the Federal Register for comment, prior to the EPA setting the final value.

2. Safety Valve. AS Trust supplied detailed information on the performance, reliability and failure rates

of suggested commercial valves in our letter/attachments to the EPA dated 18 November 2013. This 

letter was in response to the Agency’s letter of 24 September 2013 regarding Incompleteness of SNAP 

Submission on the Proposed Use of R441A (HCR188C) for Motor Vehicle Air Conditioning (MVAC) 

Systems. Our response has taken, and continues to take, the point of view of supplying information 

regarding one possible approach to implementing an optional safety valve in refrigeration/airconditioning equipment that uses the family of HCR188C pure hydrocarbon blends. We note that in an 

email from Margaret Sheppard (EPA), dated 10 July 2012, she stated, “At this time EPA does not have a 

position on the safety valve you provided. We have not taken positions on specific mitigation techniques

(AS Trust italics) in MVAC in the past; rather we have typically referenced industry standards and have 

established use conditions on refrigerant concentrations to manage risks of fire and toxicity.”

AS Trust, in discussions with two US manufacturers of air conditioning systems, has been told that nine 

out of ten times, their systems would not be built to include safety valves. These manufacturers state, 

“It’s one more part to go wrong, so unless the EPA says it’s mandatory to use such a valve, we won’t use 

it.” We discussed this point with Ms. Sheppard, explaining that manufacturers are always looking to 

control costs; they will design as required for the maximum charge, but will not add the expense of a 

safety valve unless it is also mandated.

Regarding quantified measurements of the amount of HCR188C/R443A leakage that is avoided with the 

use of a safety valve: since pressure, not charge size, is the relevant factor in the operation of the safety 

valve that we have suggested, and since HCR188C/R443A is a very similar pure hydrocarbon blend to 

HCR188C/R441A (but with an even heavier molecular weight), all leakage data/behavior would be 

similar to, or even lower than, that for HCR188C/R441A. Maximum operating pressure would be 72 psi. 

(See Parker Hannifin information for possible cartridge check-valves that could be used: 

http://www.parker.com/portal/site/PARKER/menuitem.bb22d5a82bbb5b147cf26710237ad1ca/?vgnext

oid=a2d9b5bbec622110VgnVCM10000032a71dacRCRD&vgnextchannel=a2d9b5bbec622110VgnVCM10

000032a71dacRCRD&vgnextfmt=default&vgnextcatid=3830678&vgnextcat=INSERT,%20BALL%20TYPE&

vgnextdiv=A07205&vgnextpartno=D1A025-0.2V&Wtky=)

Parker Hannifin states that the leak rate of the valve is actually tested at hydraulic pressures of 1500 to 

3000 psi (a safety factor of 20.8 to 41.7 compared to our suggested use); results show it would still only 

leak 3 drops/minute.

3. Refrigerant Recovery Equipment. Per the final rule listed in the Federal Register on 10 April 2015 (Vol. 

80, No. 69), end-of-life questions and recovery/disposal requirements do not apply to the pure 

hydrocarbon blend HCR188C/R441A. (See page 19466: On May 23, 2014, at 79 FR 29682, EPA exempted 

from the venting prohibition three hydrocarbon refrigerant substitutes, including HCR188C/R441A.

Venting is still prohibited for high GWP refrigerants such HFO-1234yf with its GWP of 600.) As a pure 
p 4

hydrocarbon blend, HCR188C/R443A (in the same family as HCR188C/R441A), has a GWP of ≤ 20 over 

100 years and therefore would also be safe to vent. 

If HCR188C/R443A were to be recovered, there are currently no testing guidelines for such a procedure. 

An employee at Intertek testing corporation who sits on the Air-conditioning, Heating and Refrigeration 

Institute (AHRI) committee for Standard 740 says that their standard was recently updated to 

accommodate equipment for flammable refrigerants but that no manufacturers have yet built any. To 

follow up on this, AS Trust has been corresponding with a well-known manufacturer of refrigerant 

recovery equipment. The latter company has stated that they have not received any direction from the 

EPA regarding flammable refrigerants, and will not be designing or testing any such equipment until 

there is more clarity from the EPA on the subject.

Inficon, a major equipment manufacturer of leak detectors, gas analyzers and other precision 

instrumentation, has been testing AS Trust products for leak detection. An Inficon company engineer 

states that recovery equipment is simply not needed, saying that if the hydrocarbons are not harmful to

the environment, why would they spend the money to build recovery equipment?

As an aside, although venting HCR188C/R443A would not harm the ozone layer or affect global warming

(the two major concerns of the EPA within the SNAP program), the refrigerant can be recovered and 

reused as fuel for barbeque systems, making its use doubly environmentally friendly.

4. Training. The EPA oversees programs that protect the ozone layer. Section 608 of the Clean Air Act 

enforces such activities that apply to stationary refrigeration and air conditioning systems. Independent 

companies such as RSES of Rolling Meadows IL provide training materials in support of such efforts and 

are authorized by the EPA to administer certification testing. The ESCO Institute (Mount Prospect, IL) 

provides a course specifically on handling hydrocarbons 

(http://www.escoinst.com/Training/HydrocarbonRefrigerants.aspx); those who complete the program 

receive an RSES certificate of completion. According to their website, ESCO Institute, a member of the 

ESCO Group, is the industry’s largest provider of EPA Section 608 certification testing.

Most refrigerant companies provide their own training guidelines specific to their brand, based on EPA 

certification requirements. For example, Linde Corporation has a document entitled “Certification 

Training Manual” (Revised 01/2015) which includes information about working with HFO-1234yf. The 

manual states that the Mobile Air Conditioning Society (MACS) Technical Training Program conforms to 

and complies with the SAE International standard J2845 “HFO-1234yf Technical Training for Service and 

Containment of Refrigerants Used in Mobile A/C Systems.” It is approved by the U.S. EPA for technical 

training requirements under Section 609 of the Clean Air Act.

For HCR188C/R443A, no industry society has yet put forth a comparable international standard on which 

to base a certification program. These groups are awaiting EPA approval for sale of HCR188C/R443A 

before funding a program to set such industry standards. Until then, installation guide materials are 

available from AS Trust (see http://www.hcr188c.com/hcrUsage.aspx for guidelines for usage and 

instructions for safe handling). Once HCR188C/R443A is approved, we assume that companies such as 

Linde Corporation will compile their own appropriate training manuals.

5. MSDS. See attached copy of the Safety Data Sheet (formerly known as Material Safety Data Sheet) for 

HCR188C/R443A, as prepared to US OSHA, CMA, ANSI and Canadian WHMIS standards by the AS Trustauthorized blending company COMSTAR, Inc.
6. CBI Claims. A.S. Trust does not wish to list any of the information submitted herein as Confidential 

Business Information. 

A.S. Trust looks forward to hearing the results of the Agency's review of our SNAP Addendum for the use 

of HCR188C/R443A in window air conditioners. 

Sincerely, 'J , / ,, ,/ / 1 ;' / '> 

j

/' ,/ '. _,/ ,/··· ~- .. · . ,./! (!;,' ;: \/ ,,:_/' ./ 

' IL /' A/~ r<'i~hard H. Maruya . ,/ / ,;:---·-

President, A. S. Trust & !foldings Inc. 

Attachment: HCR188C/R443A Safety Data Sheet 

pS 
SAFETY DATA SHEET

Prepared to U.S. OSHA, CMA, ANSI and Canadian WHMIS Standards

PART I What is the material and what do I need to know in an emergency?

1. PRODUCT IDENTIFICATION

CHEMICAL NAME; CLASS: FLAMMABLE GAS MIXTURE

HYDROCARBON GAS MIXTURE, UN 1965

March 28, 2011

MIXTURE DESCRIPTION: Flammable, liquefied gas

PRODUCT NAME:

SUPPLIER/MANUFACTURER'S NAME: ComStar International Inc.

ADDRESS: 20-45 128th Street

 College Point, NY 11356

BUSINESS PHONE: 1-718-445-7900 Toll Free: 1-800-328-0142

EMERGENCY PHONE:

2. COMPOSITION and INFORMATION ON INGREDIENTS

CHEMICAL

NAME

CAS # mole % EXPOSURE LIMITS IN AIR

ACGIH OSHA

TLV STEL PEL STEL IDLH OTHER

ppm ppm ppm ppm ppm ppm

Propane 74-98-6 0.1-80 Simple Asphyxiant 1000 NE 2100 NIOSH REL: 1000

DFG MAK: 1000

Propylene 115-07-1 0.1-80 A4 (Not 

Classifia

ble as a 

Human

Carcinog

en)

There are no specific exposure limits for Propylene. 

Propylene is a simple asphyxiant (SA). Oxygen levels 

should be maintained above 19.5%. 

Carcinogen:

IARC 3

Isobutane 75-28-5 0.1-50 There are no specific exposure limits for Isobutane. Isobutane is a simple asphyxiant (SA).

Oxygen levels should be maintained above 19.5%.

NE = Not Established See Section 16 for Definitions of Terms Used.

NOTE: All WHMIS required information is included. It is located in appropriate sections based on the ANSI Z400.1-1993 format.

1

4

HEALTH 0

FLAMMABILITY

REACTIVITY

OTHER

NFPA RATING

R443A

PRODUCT NAME: R443A
SAFETY DATA SHEET

Prepared to U.S. OSHA, CMA, ANSI and Canadian WHMIS Standards

PART I What is the material and what do I need to know in an emergency?

1. PRODUCT IDENTIFICATION

CHEMICAL NAME; CLASS: FLAMMABLE GAS MIXTURE

HYDROCARBON GAS MIXTURE, UN 1965

March 28, 2011

MIXTURE DESCRIPTION: Flammable, liquefied gas

PRODUCT NAME:

SUPPLIER/MANUFACTURER'S NAME: ComStar International Inc.

ADDRESS: 20-45 128th Street

 College Point, NY 11356

BUSINESS PHONE: 1-718-445-7900 Toll Free: 1-800-328-0142

EMERGENCY PHONE:

2. COMPOSITION and INFORMATION ON INGREDIENTS

CHEMICAL

NAME

CAS # mole % EXPOSURE LIMITS IN AIR

ACGIH OSHA

TLV STEL PEL STEL IDLH OTHER

ppm ppm ppm ppm ppm ppm

Propane 74-98-6 0.1-80 Simple Asphyxiant 1000 NE 2100 NIOSH REL: 1000

DFG MAK: 1000

Propylene 115-07-1 0.1-80 A4 (Not 

Classifia

ble as a 

Human

Carcinog

en)

There are no specific exposure limits for Propylene. 

Propylene is a simple asphyxiant (SA). Oxygen levels 

should be maintained above 19.5%. 

Carcinogen:

IARC 3

Isobutane 75-28-5 0.1-50 There are no specific exposure limits for Isobutane. Isobutane is a simple asphyxiant (SA).

Oxygen levels should be maintained above 19.5%.

NE = Not Established See Section 16 for Definitions of Terms Used.

NOTE: All WHMIS required information is included. It is located in appropriate sections based on the ANSI Z400.1-1993 format.

1

4

HEALTH 0

FLAMMABILITY

REACTIVITY

OTHER

NFPA RATING

R443A

PRODUCT NAME: R443A
3. HAZARD IDENTIFICATION 

EMERGENCY OVERVIEW: This product is a colorless, liquefied, flammable gas with an ether-like odor. This 

product poses a serious fire hazard when accidentally released. The gas may spread long distances, distant flashback 

and ignition are possible. This gas mixture can also cause symptoms of oxygen deprivation (i.e. dizziness, breathing rate 

increase). Contact with rapidly expanding gases may cause frostbite. Emergency responders must wear personal 

protective equipment appropriate for the situation to which they are responding. 

SYMPTOMS OF OVER-EXPOSURE BY ROUTE OF EXPOSURE: The 

most significant route of over-exposure for this product is by inhalation. 

INHALATION: At high concentrations Propane, a component of this 

product, can act as a narcotic. This product can cause symptoms of 

oxygen deprivation (asphyxiation) when presented in high enough 

concentrations to significantly lower oxygen concentration. Individuals 

breathing such an atmosphere may experience symptoms which include 

headaches, ringing in ears, dizziness, drowsiness, unconsciousness, 

nausea, vomiting, and depression of all the senses. Under some 

circumstances of over-exposure, death may occur. It should be noted 

that before suffocation could occur, the lower flammability limit of 

propane in air would be exceeded; possibly causing an oxygen-deficient 

and explosive atmosphere. The effects associated with various levels of 

oxygen are as follows: 

12-16% Oxygen: Breathing and pulse rate increased, muscular coordination 

slightly disturbed. 

10-14% Oxygen: Emotional upset, abnormal fatigue, disturbed respiration. 

6-10% Oxygen: Nausea and vomiting, collapse or loss of consciousness. 

Below 6%: Convulsive movements, possible respiratory collapse, and 

death. 

OTHER POTENTIAL HEALTH EFFECTS: Contact with rapidly 

expanding gases (which are released under high pressure) may cause 

frostbite. Symptoms of frostbite include change in skin color to white or 

grayish-yellow. The pain after such contact can quickly subside. 

HEALTH EFFECTS OR RISKS FROM EXPOSURE: An Explanation in 

Lay Terms. Over-exposure to this product may cause the following health effects: 

ACUTE: This gas mixture can cause symptoms of oxygen deprivation and presents a health hazard by displacing the 

oxygen in the atmosphere. Contact with rapidly expanding gases (which are released under high pressure) may cause 

frostbite. Symptoms of frostbite include change in skin color to white or grayish-yellow. 

CHRONIC: There are currently no known adverse health effects associated with chronic exposures to the components of 

this compressed gas. 

PART II What should I do if a hazardous situation occurs?

4. FIRST-AID MEASURES

RESCUERS SHOULD NOT ATTEMPT TO RETRIEVE VICTIMS OF EXPOSURE TO THIS PRODUCT 

WITHOUT ADEQUATE PERSONAL PROTECTIVE EQUIPMENT. At a minimum, Self-Contained 

Breathing Apparatus Personal Protective equipment should be worn.

Remove victim(s) to fresh air, as quickly as possible. In case of eye contact which leads to irritation, immediately flush eyes 

with copious amounts of water for at least 15 minutes. If not breathing, give artificial respiration. If breathing is difficult, give 

oxygen. Only trained personnel should administer supplemental oxygen. 

In case of frostbite, place the frostbitten part in warm water. DO NOT USE HOT WATER. If warm water is not available, or 

is impractical to use, wrap the affected parts gently in blankets. Alternatively, if the fingers or hands are frostbitten, place 

the affected area in the armpit. Encourage victim to gently exercise the affected part while being warmed. Seek immediate 

medical attention. 

HEALTH

FLAMMABILITY

REACTIVITY

PROTECTIVE EQUIPMENT

1

4

0

EYES RESPIRATORY HANDS BODY

(BLUE)

(RED)

(YELLOW)

For routine industrial applications

HAZARDOUS MATERIAL INFORMATION

SYSTEM

B

 See

 Section 8

 See

Section 8
4. FIRST-AID MEASURES (Continued)

Victim(s) must be taken for medical attention. Rescuers should be taken for medical attention, if necessary. Take copy of 

label and MSDS to physician or other health professional with victim(s). 

5. FIRE-FIGHTING MEASURES

FLASH POINT, (method): Not determined for this product. For Propane, the main 

component, the flashpoint is: -104 °C; -156 °F (Closed Cup) 

AUTOIGNITION TEMPERATURE: 450 °C; 842 °F (for Propane) 

FLAMMABLE LIMITS (in air by volume, %): 

 Lower (LEL): 2.2 for Propane 

 Upper (UEL): 9.5% for Propane 

FIRE EXTINGUISHING MATERIALS: Extinguish fire by shutting-off the source of 

the gas. Use water spray to cool fire-exposed containers, structures, and 

equipment. 

UNUSUAL FIRE AND EXPLOSION HAZARDS: When involved in a fire, this 

material may decompose and produce toxic gases including carbon monoxide and 

carbon dioxide. Additionally, when involved in fire, the cylinders may rupture. 

Vapors of this product can travel long distances to an ignition source and 

flashback.

Explosion Sensitivity to Mechanical Impact: Not Sensitive. 

Explosion Sensitivity to Static Discharge: Static discharge may cause this product to ignite explosively. 

DANGER! Fires impinging (direct flame) on the outside surface of unprotected pressure storage vessels of this product 

can be very dangerous. The resulting fire and explosion can result in severe equipment damage and personnel injury or 

death over a large area around the vessel. For massive fires in large areas, use unmanned hose holder or monitor 

nozzles; if this is not possible, withdraw from area and allow fire to burn. 

SPECIAL FIRE-FIGHTING PROCEDURES: Structural fire-fighters must wear Self-Contained Breathing Apparatus and full 

protective equipment. The best fire-fighting technique may be simply to let the burning gas escape from the pressurized 

cylinder, tank car, or pipeline. Stop the leak before extinguishing fire. If the fire is extinguished before the leak is sealed, 

the still-leaking gas could explosively re-ignite without warning and cause extensive damage, injury, or fatality. In this case, 

increase ventilation (in enclosed areas) to prevent flammable or explosive mixture formation. Evacuation may be 

necessary. Refer to the North American Emergency Response Guidebook for additional information. 

6. ACCIDENTAL RELEASE MEASURES

SPILL AND LEAK RESPONSE: Uncontrolled releases should be responded to by trained personnel using pre-planned 

procedures. Proper protective equipment should be used. In case of a release, clear the affected area, protect people, and 

respond with trained personnel. Adequate fire protection must be provided. 

Minimum Personal Protective Equipment should be Level B: Fire retardant protective clothing, mechanically-resistant 

gloves and Self-Contained Breathing Apparatus. Use only non-sparking tools and equipment. Locate and seal the 

source of the leaking gas. Protect personnel attempting the shut-off with water-spray. Allow the gas to dissipate. Monitor 

the surrounding area for Oxygen and combustible gas levels. The atmosphere must have at least 19.5 percent oxygen 

before personnel can be allowed in the area without Self-Contained Breathing Apparatus. Combustible gas concentrations 

must be below 10% of the LEL for Propane (LEL = 2.2) prior to entry. Attempt to close the main source valve prior to 

entering the area. If this does not stop the release (or if it is not possible to reach the valve), allow the gas to release inplace or remove it to a safe area and allow the gas to be released there. 

PART III How can I prevent hazardous situations from occurring?

7. HANDLING and STORAGE

WORK PRACTICES AND HYGIENE PRACTICES: As with all chemicals, avoid getting this product IN YOU. Do not eat or 

drink while handling chemicals. Be aware of any signs of dizziness or fatigue; exposures to fatal concentrations of this 

product could occur without any significant warning symptoms. All work operations should be monitored in such a way that 

emergency personnel can be immediately contacted in the event of a release. Non sparking tools should be used. 

STORAGE AND HANDLING PRACTICES: Cylinders should be stored in dry, well-ventilated areas away from sources of 

heat. Compressed gases can present significant safety hazards. Store containers away from heavily trafficked areas and 

emergency exits. Store cylinders of this gas mixture away from incompatible materials. 

SPECIAL PRECAUTIONS FOR HANDLING GAS CYLINDERS: Protect cylinders against physical damage. Store in cool, 

dry, well-ventilated area, away from sources of heat, ignition and direct sunlight. Do not allow area where cylinders are 

stored to exceed 51 C (125 F). Use a check valve or trap in the discharge line to prevent hazardous backflow. Cylinders 

should be stored upright and be firmly secured to prevent falling or being knocked over. Cylinders can be stored in the 

open, but in such cases, should be protected against extremes of weather and from the dampness of the ground to prevent 

rusting. Never tamper with pressure relief devices in valves and cylinders. The following rules are applicable to situations 

in which cylinders are being used: 

1

4

HEALTH 0

FLAMMABILITY

REACTIVITY

OTHER

NFPA RATING
Before Use: Move cylinders with a suitable hand-truck. Do not drag, slide or roll cylinders. Do not drop cylinders or permit 

them to strike each other. Secure cylinders firmly. Leave the valve protection cap in-place until cylinder is ready for use.

During Use: Use designated CGA fittings and other support equipment. Do not use adapters. Do not heat cylinder by 

any means to increase the discharge rate of the product from the cylinder. Use check valve or trap in discharge line to 

prevent hazardous backflow into the cylinder. Do not use oils or grease on gas-handling fittings or equipment. 

After Use: Close main cylinder valve. Replace valve protection cap. Mark empty cylinders “EMPTY”.

NOTE: Use only DOT or ASME code containers. Earth-ground and bond all lines and equipment associated with this 

product. Close valve after each use and when empty. Cylinders must not be recharged except by or with the consent of 

owner. For additional information refer to the Compressed Gas Association Pamphlet P-1, Safe Handling of Compressed 

Gases in Containers. Additionally, refer to CGA Bulletin SB-2 “Oxygen Deficient Atmospheres”. 

PROTECTIVE PRACTICES DURING MAINTENANCE OF CONTAMINATED EQUIPMENT: Follow practices indicated in 

Section 6 (Accidental Release Measures). Make certain application equipment is locked and tagged-out safely. Purge gas 

handling equipment with inert gas (i.e. nitrogen) before attempting repairs. Always use product in areas where adequate 

ventilation is provided. 

8. EXPOSURE CONTROLS - PERSONAL PROTECTION

VENTILATION AND ENGINEERING CONTROLS: Use with adequate ventilation to ensure exposure limits are maintained 

below those described in Section 2 (Composition and Information on Ingredients). Local exhaust ventilation is preferred, 

because it prevents dispersion of this gas mixture into the work place by eliminating it at its source. If appropriate, install 

automatic monitoring equipment to detect the level of Oxygen. Eye wash stations/safety showers should be near areas 

where this product is used or stored. 

RESPIRATORY PROTECTION: Maintain oxygen levels above 19.5% in the workplace. Use supplied air respiratory 

protection if oxygen levels are below 19.5% or during emergency response to a release of this product. If respiratory 

protection is required, follow the requirements of the Federal OSHA Respiratory Protection Standard (29 CFR 1910.134), or 

equivalent State standards. For additional information, the NIOSH recommended protection guidelines for Propane 

are provided as follows: 

NIOSH RECOMMENDATIONS FOR PROPANE CONCENTRATIONS IN AIR: 

UP TO 2100 PPM: Supplied-air respirator operated or Self Contained Breathing Apparatus with a full facepiece. 

EMERGENCY OR PLANNED ENTRY INTO UNKNOWN CONCENTRATIONS OR IDLH CONDITIONS: 

Positive pressure, full-facepiece Self Contained Breathing Apparatus; or positive pressure, full-facepiece Self Contained Breathing Apparatus 

with an auxiliary positive pressure Self Contained Breathing Apparatus. 

ESCAPE: 

Escape-type Self Contained Breathing Apparatus. 

EYE PROTECTION: Splash goggles, face-shields or safety glasses. 

HAND PROTECTION: Wear mechanically-resistant gloves when handling cylinders of this product. Wear chemicallyresistant gloves when using this gas mixture. Butyl rubber, chlorinated polyethylene, neoprene nitrile, and polyvinyl rubber 

are recommended. 

BODY PROTECTION: Use body protection appropriate for task. 

9. PHYSICAL and CHEMICAL PROPERTIES

The following information is for Propane, the main component of this product:

VAPOR DENSITY: 1.868 kg/m3

 pH: Not applicable. 

SPECIFIC GRAVITY (air =1): 1.550 FREEZING POINT: -187.70 C (-305.9F) 

SOLUBILITY IN WATER: Very slight. BOILING POINT(°F @ 1 atm.): (-43.7 F) -42 C 

EVAPORATION RATE (nBuAc = 1): Not applicable. EXPANSION RATIO: Not available. 

ODOR THRESHOLD: 22,000-36,000 mg/m3 VAPOR PRESSURE (psia): 123.7 

COEFFICIENT WATER/OIL DISTRIBUTION: 2.36 SPECIFIC VOLUME (ft3/lb): 8.7

APPEARANCE AND COLOR: This product is a colorless gas with a natural gas smell. 

HOW TO DETECT THIS SUBSTANCE (warning properties): There are no distinct warning properties. In terms of leak 

detection, fittings and joints can be painted with a soap solution to detect leaks, which will be indicated by a bubble 

formation.

10. STABILITY and REACTIVITY 

STABILITY: Normally stable in gaseous state. 

DECOMPOSITION PRODUCTS: When ignited in the presence of oxygen, this gas will burn to produce carbon monoxide 

and carbon dioxide. 

MATERIALS WITH WHICH SUBSTANCE IS INCOMPATIBLE. This product is not compatible with strong oxidizers. 

HAZARDOUS POLYMERIZATION: Will not occur. 
CONDITIONS TO AVOID: Contact with incompatible materials and exposure to heat, sparks and other sources of ignition. 

Cylinders exposed to high temperatures or direct flame can rupture or burst. 

PART III How can I prevent hazardous situations from occurring?

11. TOXICOLOGICAL INFORMATION

TOXICITY DATA: The following toxicology data are for the components of this gas mixture present at a level greater than 1 

mole %: 

SUSPECTED CANCER AGENT: None of the components of this gas mixture are found on the following lists: FEDERAL 

OSHA Z LIST, NTP, CAL/OSHA, IARC, and are therefore not considered to be, nor suspected to be, cancer-causing 

agents by these agencies. 

IRRITANCY OF PRODUCT: Contact with rapidly expanding gases can cause frostbite and damage to exposed skin and 

eyes. 

SENSITIZATION OF PRODUCT: Propylene, Propane, and i-Butane (components of this product) are not known to cause 

sensitization in humans; however, some animals studies indicate that exposure to these gases can cause weak cardiac 

sensitization. 

REPRODUCTIVE TOXICITY INFORMATION: Listed below is information concerning the effects of this product and its 

components on the human reproductive system. 

Mutagenicity: This product is not reported to cause mutagenic effects in humans. 

Embryotoxicity: This product is not reported to cause embryotoxic effects in humans. 

Teratogenicity: This product is not reported to cause teratogenic effects in humans. 

Reproductive Toxicity: This product is not reported to cause adverse reproductive effects in humans. 

A mutagen is a chemical which causes permanent changes to genetic material (DNA) such that the changes will propagate 

through generation lines. An embryotoxin is a chemical which causes damage to a developing embryo (i.e. within the first 

eight weeks of pregnancy in humans), but the damage does not propagate across generational lines. A teratogen is a 

chemical which causes damage to a developing fetus, but the damage does not propagate across generational lines. A 

reproductive toxin is any substance which interferes in any way with the reproductive process.

MEDICAL CONDITIONS AGGRAVATED BY EXPOSURE: Acute or chronic respiratory conditions may be aggravated by 

over-exposure to the components of this product. 

RECOMMENDATIONS TO PHYSICIANS: Administer oxygen, if necessary; treat symptoms eliminate exposure. 

BIOLOGICAL EXPOSURE INDICES: Currently, there are no Biological Exposure Indices (BEIs) associated with the 

components of this product. 

12. ECOLOGICAL INFORMATION

ENVIRONMENTAL STABILITY: This gas will be dissipated rapidly in well-ventilated areas. The components of the gas 

mixture are stable in the environment. 

EFFECT OF MATERIAL ON PLANTS or ANIMALS: Any adverse effect on animals would be related to oxygen deficient 

environments, as a well as respiratory system damage. Frost-produced in the presence of rapidly expanding gases may 

adversely affect plant life. 

EFFECT OF CHEMICAL ON AQUATIC LIFE: No evidence is currently available on this product’s effects on aquatic life. 

However, all work practices should be aimed at eliminating contamination of aquatic environments with this product. 

13. DISPOSAL CONSIDERATIONS

PREPARING WASTES FOR DISPOSAL: Waste disposal must be in accordance with appropriate Federal, State, and local 

regulations. Return cylinders with residual product to MESA. Do not dispose of locally. 

14. TRANSPORTATION INFORMATION
THIS MATERIAL IS HAZARDOUS AS DEFINED BY 49 CFR 172.101 BY THE U.S. DEPARTMENT OF

TRANSPORTATION.

PROPER SHIPPING NAME: Hydrocarbon gas mixture n.o.s. (Propane, Propylene)

HAZARD CLASS NUMBER and DESCRIPTION: 2.1 (Flammable Gas)

UN IDENTIFICATION NUMBER: UN 1965

PACKING GROUP: Not applicable

DOT LABEL(S) REQUIRED: Flammable Gas

NORTH AMERICAN EMERGENCY RESPONSE GUIDEBOOK NUMBER (1996): 115

MARINE POLLUTANT: The components of this gas mixture are not classified by the DOT as Marine Pollutants (as defined

by 49 CFR 172.101, Appendix B).

TRANSPORT CANADA, TRANSPORTATION OF DANGEROUS GOODS REGULATIONS: THIS MATERIAL IS

CONSIDERED AS DANGEROUS GOODS. Use the above information for the preparation of Canadian Shipments.

15. REGULATORY INFORMATION

SARA REPORTING REQUIREMENTS: The components of this gas mixture are subject to the reporting requirements of

Sections 302, 304 and 313 of Title III of the Superfund Amendments and Reauthorization Act., as follows:

COMPONENT SARA 302 SARA 304 SARA 313

Propylene NO NO NO

Iso-Butane NO NO NO

Propane NO NO YES

OTHER FEDERAL REGULATIONS: Propylene, Isobutane and Propane are subject to the reporting requirements of

Section 112(r) of the Clean Air Act. The Threshold Quantity for each of these gases is 10,000 pounds. Depending on

specific operations involving the use of this product, the regulations of the Process Safety Management of Highly

Hazardous Chemicals may be applicable (29 CFR 1910.119). This regulation is pertinent when the total amount of

flammable gas on site is above 10,000 lbs.

STATE REGULATORY INFORMATION: The components of this gas mixture are covered under specific State regulations,

as denoted below:

Alaska - Designated Toxic and

Hazardous Substances: Methane,

Propane, Butane, Ethane.

California - Permissible Exposure

Limits for Chemical Contaminants:

Methane, Propane, Butane, Ethane.

Florida - Substance List: None.

Illinois - Toxic Substance List:

Methane, Butane, Ethane.

Kansas - Section 302/313 List: Ethane.

Massachusetts - Substance List:

Methane, Propane, Butane,

Isobutane.

Minnesota - List of Hazardous

Substances: Methane, Propane,

Butane, Ethane.

Missouri - Employer Information/Toxic

Substance List: Methane, Propane,

Butane, Ethane.

New Jersey - Right to Know Hazardous

Substance List: Methane, Propane,

Butane, Ethane, Isobutane.

North Dakota - List of Hazardous

Chemicals, Reportable Quantities:

None.

Pennsylvania - Hazardous Substance

List: Methane, Propane, Butane,

Ethane 2-Methyl-Propane.

Rhode Island - Hazardous Substance

List: Methane, Propane, Butane,

Ethane.

Texas - Hazardous Substance List:

Propane.

West Virginia - Hazardous Substance

List: Propane.

Wisconsin - Toxic and Hazardous

Substances: Propane.

CALIFORNIA PROPOSITION 65: No component of this product is on the California Proposition 65 lists.

LABELING (For Compressed Gas):

DANGER: FLAMMABLE LIQUID AND GAS UNDER PRESSURE.

CAN FORM EXPLOSIVE MIXTURES WITH AIR.

MAY CAUSE FROSTBITE.

Keep away from heat, flames, and sparks.

Store and use with adequate ventilation.

Cylinder temperature should not exceed 125 F (52 C).

Do not get liquid in eyes, on skin or clothing.

Close valve after each use and when empty.

Use in accordance with the Material Safety Data Sheet.

FIRST-AID: IF INHALED, remove to fresh air. If not breathing, give artificial respiration. If breathing is

difficult, give oxygen. Call a physician.

DO NOT REMOVE THIS PRODUCT LABEL.

TARGET ORGANS: Respiratory system.

WHMIS SYMBOLS: A: Compressed Gas

B-1: Flammable Gas
DEFINITIONS OF TERMS

A large number of abbreviations and acronyms appear on a MSDS.

 Some of these which are commonly used include the following:

CAS #: This is the Chemical Abstract Service Number which

uniquely identifies each constituent. It is used for computer-related

searching.

EXPOSURE LIMITS IN AIR:

ACGIH - American Conference of Governmental Industrial

Hygienists, a professional association which establishes exposure

limits.

TLV - Threshold Limit Value - an airborne concentration of a

substance which represents conditions under which it is generally

believed that nearly all workers may be repeatedly exposed without

adverse effect. The duration must be considered, including the 8-

hour Time Weighted Average (TWA), the 15-minute Short Term

Exposure Limit, and the instantaneous Ceiling Level. Skin

adsorption effects must also be considered.

OSHA - U.S. Occupational Safety and Health Administration.

PEL - Permissible Exposure Limit - this exposure value means

exactly the same as a TLV, except that it is enforceable by OSHA. 

The OSHA Permissible Exposure Limits are based in the 1989

PELs and the June, 1993 Air Contaminants Rule (Federal Register:

58: 35338-35351 and 58: 40191). Both the current PELs and the

vacated PELs are indicated. The phrase, “Vacated 1989 PEL”, is

placed next to the PEL which was vacated by Court Order.

IDLH - Immediately Dangerous to Life and Health level

represents a concentration from which one can escape within 30-

minutes without suffering escape-preventing or permanent injury.

The DFG - MAK is the Republic of Germany’s Maximum Exposure

Level, similar to the U.S. PEL. NIOSH is the National Institute of

Occupational Safety and Health, which is the research arm of the

U.S. Occupational Safety and Health Administration (OSHA).

NIOSH issues exposure guidelines called Recommended Exposure

Levels (RELs). When no exposure guidelines are established, an

entry of NE is made for reference.

FLAMMABILITY LIMITS IN AIR:

Much of the information related to fire and explosion is derived from

the National Fire Protection Association (NFPA). LEL - the lowest

percent of vapor in air, by volume, that will explode or ignite in the

presence of an ignition source. UEL - the highest percent of vapor in

air, by volume, that will explode or ignite in the presence of an

ignition source.

TOXICOLOGICAL INFORMATION:

Possible health hazards as derived from human data, animal

studies, or from the results of studies with similar compounds are

presented. Definitions of some terms used in this section are: LD50 -

Lethal Dose (solids & liquids) which kills 50% of the exposed

animals; LC50 - Lethal Concentration (gases) which kills 50% of the

exposed animals; ppm concentration expressed in parts of material

per million parts of air or water; mg/m3 concentration expressed in

weight of substance per volume of air; mg/kg quantity of material,

by weight, administered to a test subject, based on their body weight

in kg. Data from several sources are used to evaluate the cancercausing potential of the material. The sources are: IARC - the

International Agency for Research on Cancer; NTP - the National

Toxicology Program, RTECS - the Registry of Toxic Effects of

Chemical Substances, OSHA and CAL/OSHA. IARC and NTP rate

chemicals on a scale of decreasing potential to cause human

cancer with rankings from 1 to 4. Subrankings (2A, 2B, etc.) are

also used. Other measures of toxicity include TDLo, the lowest dose

to cause a symptom and TCLo the lowest concentration to cause a

symptom; TDo, LDLo, and LDo, or TC, TCo, LCLo, and LCo, the

lowest dose (or concentration) to cause death. BEI - Biological

Exposure Indices, represent the levels of determinants which are

most likely to be observed in specimens collected from a healthy

worker who has been exposed to chemicals to the same extent as a

worker with inhalation exposure to the TLV.

REGULATORY INFORMATION:

This section explains the impact of various laws and regulations on

the material. EPA is the U.S. Environmental Protection Agency.

WHMIS is the Canadian Workplace Hazardous Materials

Information System. DOT and TC are the U.S. Department of

Transportation and Transport Canada, respectively. These are:

Superfund Amendments and Reauthorization Act (SARA); the

Toxic Substance Control Act (TSCA); Marine Pollutant status

according to the DOT; California's Safe Drinking Water Act

(Proposition 65); the Comprehensive Environmental Response,

Compensation, and Liability Act (CERCLA or Superfund); and

various state regulations. This section also includes information on

the precautionary warnings which appear on the materials package

label.

The information contained herein is based on data considered accurate. However, no warranty is expressed or implied regarding the accuracy of these data or

the results to be obtained from the use thereof. ComStar assumes no responsibility for injury to the vendee or third persons proximately caused by the material if

reasonable safety procedures are not adhered to as stipulated in the data sheet. Additionally, ComStar assumes no responsibility for injury to vendee or third

persons proximately caused by abnormal use of the material even if reasonable safety procedures are followed. Furthermore, vendee assumes the risk in his

use of the material.