Epichlorohydrin Safety

Product Stewardship ManualSafe Handling and Storage

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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 ContentsDO

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Epichlorohydrin is a highlyreactive chemical intermediate

available since 1957 from The DowChemical Company (Dow). Today,Dow is one of the largest producersof epichlorohydrin in the world, witha capacity of more than 450,000metric tons/year (more than 1 billionpounds/year) from plants in Freeport,Texas, U.S.A., and Stade, Germany.

In its pure form, epichlorohydrin is aclear, colorless liquid. The presenceof both an epoxide ring and achlorine atom in the molecule allowsepichlorohydrin to readily undergo avariety of chemical reactions withmany types of compounds. Thisversatility earns its wide use as achemical intermediate.

Regardless of its uses,epichlorohydrin must be handledcarefully to protect the health ofemployees, customers, the public,and the environment. Although yourcompany is responsible for its ownsafety procedures, our goal is tomake that task easier with thismanual.

Read it prior to handling or usingepichlorohydrin products, and use itas a training tool for new employees.For additional assistance, you canask Dow to:

• Support your engineering andindustrial hygiene monitoringprograms;

• Make a pre-delivery evaluation ofyour site and provide suggestionsfor improvement;

• Conduct on-site training for youremployees;

• Attend the first delivery to assist ina safe and spill-free producttransfer.

We want to put our experience withepichlorohydrin to work for you.

Product StewardshipDow and its employees have afundamental concern for all whomake, distribute, and use itsproducts, and for the environment inwhich we live. This concern is thebasis for our Product Stewardshipphilosophy by which we assess thehealth and environmentalinformation on our products andtake appropriate steps to protectemployee and public health and ourenvironment. Our ProductStewardship program rests with eachand every individual involved withDow products, from initial conceptand research, to the manufacture,sale, distribution, use, and recyclingor disposal of each product.

Responsible Care®

Dow has a long-standing policy toensure that its operations do nothave an adverse impact on thecommunity or the environment. Touphold this policy, Dow is committedto Responsible Care®, a continuingeffort by the chemical industry toimprove the responsible managementof chemicals.

Under Responsible Care, Dowcomplies with 10 Guiding Principlesand Codes of Management Practicesthat cover all aspects of research,development, manufacture,distribution, transportation, use, anddisposal of products. Theseprinciples also extend to promptreporting, customer counseling,community awareness, support ofexternal research, participation withgovernment and others, andpromotion of Responsible Careworldwide.

Introduction

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Dow recognizes that no single entitycan protect the quality of all of ourair and water. However, by workingtogether on a global basis, the public,industry, and government can makethe future brighter and safer.

There are joint European ChemicalIndustry Council(CEFIC)/theEuropean Association of ChemicalDistributors (FECC) ResponsibleCare guidelines available via CEFIC’sweb page, www.cefic.org, and onwww.responsiblecare.org.

Customer NoticeDow encourages its customers andpotential users of Dow products toreview their applications for suchproducts from the standpoint ofhuman health and environmentalquality. To help ensure that Dowproducts are not used in ways forwhich they were not intended ortested, Dow personnel are availableto assist customers in dealing withecological and product safetyconsiderations. Your Dow salesrepresentative can arrange for theproper contacts. Dow literature,including Material Safety DataSheets (MSDSs) or Safety DataSheets (SDSs), should be consultedprior to the use of Dow products.Or visit our Product Safety web site,www.dow.com/productsafety.

Dow believes the information andsuggestions contained in this manualto be accurate and reliable as ofJanuary 2007. However, since anyassistance furnished by Dow withreference to the proper use anddisposal of its products is providedwithout charge, and since useconditions and disposal are notwithin its control, Dow assumes noobligation or liability for suchassistance and does not guaranteeresults from use of such products orother information herein. Nowarranty, express or implied, is givennor is freedom from any patentowned by Dow or others to beinferred.

Information herein concerning lawsand regulations is based on U.S.federal laws and regulations exceptwhere specific reference is made tothose of other jurisdictions. Sinceuse conditions and governmentrequirements may differ from onelocation to another and may changewith time, it is the customer’sresponsibility to determine whetherDow’s products are appropriate forthe customer’s use, and to assure thatthe customer’s workplace anddisposal practices comply withapplicable government requirements.

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This Product Stewardship manual contains important information aboutDOW™ 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 suggestionsfor handling, storage, and disposal from the appropriate suppliers prior toworking with those materials.

For more information about DOW Epichlorohydrin, refer to the MSDS/SDSor contact your Dow representative. See the Appendix for country-specificcontacts and telephone numbers. For emergencies, call the Dow EmergencyResponse 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 ResponseNetwork with national emergency centers)(1)

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™ 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 throughthe European Emergency Reponse Network.

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Physical PropertiesThe chemical structure ofepichlorohydrin is shown in Figure 1.Physical properties are provided inTable 2 and in Figures 2 and 3.Typical chemical reactions areprovided in Table 3.

Chemical ReactivityAt high temperatures,epichlorohydrin can react violentlyand in some cases explosively(spontaneous polymerization) in thepresence of certain substances. Thesesubstances may include:

• Acids

• Alcohols

• Alkalis

• Aluminum, magnesium, copper,tin, zinc, and other alloys

• Amines

• Ammonia

• Carbon monoxide

• Metal halides (such as ironIII-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 106-89-8ID Number (Annex I*) 603-026-00-6EC Number (EINECS) 203-439-8

Chemical Name 1-chloro-2,3-epoxypropane

Common Name Epichlorohydrin (ECH or EPI)

Decomposition Temperature 217˚C (423˚F)

Densitylb/gal, at 25˚C 9.8g/l 1,174.5lb/ft3 73.3

Dielectric Constant, at 20˚C 23

Empirical Formula C3 H5 OCl

Flammable Limits, Volume in AirLower Limit (%) 3.8Upper Limit (%) 21

Flammable Limits, Volume Oxygen inEpichlorohydrin

Lower Limit (%) 11.6

Evaporation Rate 1.35 (butyl acetate = 1)

Flash Point, TCC (Tag Closed Cup) 31˚C (87.8˚F)

Heat CapacityJ/mol, at 25˚C 131.9 (31.5 cal/mol)J/mol, at 100˚C 166.2 (39.7 cal/mol)

Heat of FormationkJ/mol, at 25˚C -149.0 (-35.6 kcal/mol)BTU/lb, at 77˚F -693.1

Heat of FusionkJ/mol, at 25˚C 10.5 (2,500 cal/mol)Btu/lb, at 77˚F 49

(Table continued)

H2C––CH––CH2CI

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Note: A mixture of epichlorohydrinand water, in which a two-phasemixture forms, will create aparticular hazard (see Table 2,solubility information). Over time,an exothermic reaction will start atthe interface which can generateenough heat to create a pressurebuild-up in the tank. Such mixturesmust be disposed of promptly (seepage 21, “Emergency Preparedness,”for disposal information).

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

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

Property Description

Heat of HomopolymerizationkJ/mol, at 25˚C 101.7 (24.3 kcal/mol)

Heat of VaporizationkJ/mol, at 25˚C 42.4 (10.1 kcal/mol)Btu/lb, at 77˚F 196.9

Oxygen Content Required for 11.6Combustion, 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) 10Odor recognized by majority 25of individuals (ppm)

Refractive Index nD20 1.435

Saturated Concentration 1.7(% volume in air at 20˚C (68˚F)

Solubility, at 25˚CAcetone InfiniteBenzene InfiniteCarbon Tetrachloride InfiniteDiethylether Infiniten-Heptane InfiniteMethanol InfiniteIn Water, at 20˚C (%) 6.6Water In, at 20˚C (%) 1.5

Specific Gravity, at 25/25˚C 1.178

Specific Heat Ratio, at 25˚C 1.1131

Surface TensionN/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).

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Figure 2: Vapor Pressure of Epichlorohydrin (1)

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Figure 3: Density of Epichlorohydrin (1)

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




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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 Acidsand 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––CH(OOCR)––CH2CIAnhydrides

CH2––CH––CH2CI + RCOCI

O

CH2CI––CH(OOCR)––CH2CIAcyl ChloridesR H

O OC

CH2––CH––CH2CI + RCHO CICH2––CH––CH2Aldehydes

O

R R1

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CH2––CH––CH2CI + RCOR1 CICH2––CH––CH2Ketones

O

CH2––CH––CH2CI + RHNH RHNCH2––CHOH––CH2CIAmines

O

CH2––CH––CH2CI + RMgBr CH2R––CHOMgBr––CH2CIGrignard Reagents

O

CCH2R––CHOH––CH2CI CH2OMgBr––CHR––CH2CIH2O +

CH2OH––CHR––CH2CI+

CH2––CH––CH2CI + HOH CH2OH––CHOH––CH2CIWater

O

CH2––CH––CH2CI CH2OH––CHOH––CH2OH + NaCIWater and

Sodium Hydroxide

O

CH2––CH––CH2CI + HCI CH2CI––CHOH––CH2CIInorganic Acidsand Salts

O

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

OH2O

CH2––CH––CH2CI + RSH RS––CH2––CHOH––CH2CIOrganic Sulfur

O

CH2––CH––CH2CI + RSH

O

R––S––CH2––CH––CH2 + NaCI + H2ONaOH

O

Table 3: Typical Reactions of Epichlorohydrin

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Product UsesEpichlorohydrin is an extremelyversatile chemical intermediate thatfinds its use in a wide variety ofapplications - from epoxy resins andtextiles, to ion exchange resins,rubbers, agricultural products, andmore.

Epoxy ResinsEpichlorohydrin is primarily used tomanufacture epoxy resins. Epoxyresins are generally produced byreacting a polyhydric phenol with analiphatic chlorohydrin or simplealiphatic epoxide. The most familiarepoxy is obtained by condensingepichlorohydrin with bisphenol A,resulting in a basic epoxy resinmolecule, such as that shown inFigure 4.

Major advantages of epoxy resinsinclude corrosion resistance, solventand 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 activehydrogen, such as aldehydes, polyamides, and polyamines.

• Crosslinking it with amine or acid curing agents.

• Esterifying it with short- or long-chain unsaturated acids.

TextilesIn the textile industry, epichlorohydrin is used to modify the carboxyl groupsof wool. The resulting product has a longer and improved resistance tomoths. Epichlorohydrin also is used to prepare protein-modified, wool-likefibers which have an affinity for acid dyes and which exhibit resistance toboth mold and insects.

Further, epichlorohydrin is used to prepare dyeable polypropylene fibers andto dye polyolefin, polyacrylonitrile, polyvinyl chloride, polyvinyl alcohol, andother fibers. It is also used to impart wrinkle resistance and to prepare anti-static agents and textile sizings.

Derivatives of epichlorohydrin show utility as leveling, dispersion, softening,emulsifying and washing agents.

Papers, Inks, DyesWet-strength paper sizing is prepared from either polyamides modified withepichlorohydrin or from the reaction product of epichlorohydrin and analkylene amine.

Epichlorohydrin polyhydroxy compounds and their esters are useful in theproduction of special printing inks and textile print pastes. These productsyield flexible films that are chemically inert to caustic soda and other chemicalsolutions.

Epichlorohydrin adducts are useful as filler retention aids, paper coatings,flocculants, and anti-static agents. Paper and paperboard products withimproved printability, pigment retention, folding endurance, and gloss also areprepared with epichlorohydrin reaction products.

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Ion Exchange Resins

Epichlorohydrin is used to produceboth anion- and cation-exchangeresins. Water-insoluble anion-exchange resins having good stabilityare prepared by reactingepichlorohydrin withethylenediamine or a higherhomolog. Strong-base anion-exchange resins can be produced byreacting epichlorohydrin withpolymeric tertiary amines.Epichlorohydrin-based anionexchangers are used successfully topurify drinking water and to cleanpolluted air.

Cation-exchange resins are producedby condensing epichlorohydrin withpolyhydroxy phenols and bysulfonating the product.

Surface Active AgentsMany epichlorohydrin-based,surface-active agents are synthesizedby condensing the epichlorohydrinwith a polyamine such astetraethylene-pentamine, plus a fattyacid such as stearic acid.

The polyamine and fatty acid may bereplaced with an alkali metal, starch,or other reactant. Sulfonatedepichlorohydrin is occasionallysubstituted for epichlorohydrin.Such products find use in cosmeticsand shampoos, and as detergents,sudsing agents, water softeners, anddemulsifiers.

Epichlorohydrin-Based RubberEpichlorohydrin is polymerized orcopolymerized with ethylene oxide toform elastomers. These elastomers,members of a family of specialtypolyether rubbers, possess excellentphysical properties over a wide rangeof temperatures and are resistant tofuel, oil, and ozone. Otheradvantages are excellent agingcharacteristics, high resiliency, andflexibility at low temperatures.

Applications for epichlorohydrin-based rubber include automotive andaircraft parts, seals and gaskets, wireand cable jackets, adhesives,packings, hose and belting, rubber-coated fabrics, and energy absorbingunits.

PlasticizersThe reaction of epichlorohydrin withalcohols, alcoholates, or the sodiumsalts of stearic, oleic, palmitic,myristic, and other fatty acids yieldsproducts used as vinyl polymerplasticizers, solvents for food andflavoring, and plasticizers forpolyurethanes.

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Agricultural ProductsBiologically active compounds areprepared by reacting epichlorohydrinwith alcohols or the sodium salts ofalkylphenols. Such products havefound effective use in insecticides,bactericides, and fungicides.

More ApplicationsOther applications for derivatives ofepichlorohydrin 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

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Health, Safety, and Handling

The information in this section is general and should be used inconjunction with the most current epichlorohydrin MSDS/SDS. A

current MSDS/SDS can be obtained from your Dow representative or bycalling the Dow Customer Information Group (CIG) at +1 800 441-4369 inthe United States. MSDS/SDS can also be obtained from the Dow Internethome page, www.dow.com. The MSDS/SDS should be reviewed prior toworking with epichlorohydrin.

Health Hazards

Odor Threshold and Warning PropertiesEpichlorohydrin has a sweet, pungent smell with an odor threshold variouslyreported at values less than 1 part per million (ppm) to 25 ppm. Sensoryperception studies have indicated that the mean threshold for odor recognitionof epichlorohydrin is 10 ppm, and that at 25 ppm it is recognized by themajority of persons. These findings are supported by the epichlorohydrinsubcommittee of the Society of the Plastics Industry (SPI), in its publication,“Epichlorohydrin, Safety and Handling Guide,” September 1994. Markednose 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 awarning or indicator of exposure potentials.

For more information, refer to:

• Odor as an Aid to Chemical Safety: Odor Thresholds Compared WithThreshold Limit Values and Volatilities for 214 Industrial Chemicals in Airand Water Dilution, J.E. Amoore and E. Hautala, Journal of AppliedToxicology, Vol. 3, No. 6, 1983.

• Odor Thresholds and Irritation Levels of Several Chemical Substances: AReview, 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 EffectsExcessive vapor concentrations are readily attainable at room temperatureand may cause unconsciousness and death. At 25˚C (77˚F), epichlorohydrinhas a vapor pressure of 2.26 kPa (17 mmHg). This is equivalent to 22,000ppm by volume. The one-hour LC50 value is 3617 ppm for male rats and2165 ppm for female rats.

InhalationEpichlorohydrin vapor is irritating to the mucous membranes of therespiratory tract. Lung injury, which may be delayed, can result frominhalation of epichlorohydrin vapor. Liver and kidney injury can result fromrespiratory exposure or prolonged skin contact.

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IngestionWhile epichlorohydrin does displaymoderate acute oral toxicity (the oralLD50 has been reported in the rangeof 175-282 mg/kg, depending on theparticular species tested), it isunlikely that acutely toxic amountsof epichlorohydrin would be ingestedin the course of ordinary operations.However, should appreciableamounts be willfully or accidentallyingested, serious injury, includingdeath, could result. Epichlorohydrin,therefore, should be kept in theoriginal containers (appropriatelylabeled), which should be closed andkept away from personsinexperienced with proper handlingand use.

Contact EffectsThe following effects ofepichlorohydrin on the skin and eyesshould be carefully noted by allindividuals working with thismaterial.

Skin ContactEpichlorohydrin is irritating and canbe damaging to the skin, particularlyif contact exceeds a few minutes.Exposure may not be apparent andirritation or damage may not developfor several hours. Prolonged contactwill invariably cause serious chemicalburns, even at low concentrations.Epichlorohydrin has caused allergicskin reactions in humans and istherefore classified as a skin sensitizer.Epichlorohydrin is also readilyabsorbed through intact skin inharmful amounts (the LD50 for skinabsorption in rabbits is 515 mg/kg).Systemic intoxication from repeatedskin contacts can be hazardous.

Eye ContactEye contact with epichlorohydrinliquid will produce moderateirritation with corneal injury.Solutions of epichlorohydrin maycause more irritation and injury if thesolvent carrying the epichlorohydrinis miscible with water.Epichlorohydrin vapor is also veryirritating to the eyes.

Chronic Toxicity - Systemic EffectsRepeated inhalation ofepichlorohydrin vapor has resulted inliver and kidney injury to laboratoryanimals. In animal studies, areversible decrease in fertility wasobserved in male rats; however, anumber of epidemiological studieswhich investigated epichlorohydrinexposure and health effects inworkers have shown no associationwith reproduction effects.

Burn PotentialThe chemical burn potential withepichlorohydrin is well-known andidentified in the MSDS/SDS as ahazard.

In an actual chemical burn incident,a worker wearing leather bootsreceived a small splash on hisimpervious outer (slicker) suit duringa truck off-loading operation. Theworker washed the contaminationfrom the suit shortly after theincident and again before storing thesuit. He was unaware that a minorcontamination of his boot hadoccurred.

Approximately eight hours after theexposure, the worker noted itchingon one of his feet. He noted threeirritating red spots on his foot, butdid not recognize them as anepichlorohydrin burn and put theleather boot back on his foot. Thefollowing morning, the workerawoke with a very swollen foot anda large blister across the area wherethe irritation was first observed.

A medical investigation indicatedthat he had a severe burn which wasbelieved to be caused by the verysmall epichlorohydrin exposure thatoccurred on the previous day. Theburn required skin grafts and eightweeks to heal.

This incident reinforces the followingobservations:

• Leather does not offer suitableprotection when handlingepichlorohydrin and may magnifythe burn potential.

• Even an apparently insignificantexposure can lead to a serious burnif the contact continues for anextended period of time.

• After leather is contaminated, itcannot be decontaminated andtherefore must be destroyed.

• The specific manufacturer’s data onpersonal protective clothing (e.g.,gloves, boots, and slicker suits)should be reviewed to ensure theirsuitability for use.

• All terminal valves and fittingsshould be plugged to reduce thelikelihood of an accidentalexposure.

Carcinogen PotentialEpichlorohydrin has been shown tocause cancer in laboratory animals.In the U.S.A. it is considered to be apotential carcinogen for purposes ofthe Occupational Safety and HealthAdministration’s (OSHA) hazardcommunication standard, 29 CFR1910.1200. It is classified by theInternational Agency for Research onCancer (IARC) as 2A (probablycarcinogenic in humans). TheAmerican Conference ofGovernmental Industrial Hygienists(ACGIH) classifies epichlorohydrinto cancer class A3 (confirmed animalcarcinogen with unknown relevanceto humans).

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In Europe, the Dangerous SubstancesDirective 67/548/EEC and theupdates thereto classifyepichlorohydrin as a Category 2carcinogen (carcinogenic in animals).The directive further requires thedescription of epichlorohydrin asfollows: “The substance should beregarded as if it is carcinogenic toman. There is sufficient evidence toprovide a strong presumption thathuman exposure to the substancemay result in the development ofcancer.”

Various epidemiological studies,however, have not supported thecontention that epichlorohydrin iscarcinogenic to humans. For moreinformation refer to the followingresources:

• Retrospective Cohort MortalityStudy of Workers With PotentialExposure to Epichlorohydrin andAllyl Chloride. G.W. Olsen, et al.,American Journal of IndustrialMedicine, (1994), 25(2), 205-18

• IARC report Vol. 71 (1999) p 603,Section 5 Summary of DataReported and Evaluation, availableat http://www-cie.iarc.fr htdocs/monographs/vol71/020-epichlorohydrin.html

Preventive ExaminationsBefore workers are assigned toepichlorohydrin handling operations,they should be screened with acomplete pre-placementexamination.

Note: Individuals with medicalconditions that involve impairment ofthe liver, kidney, heart, or respiratorytract (which may include impairmentdue to abuse of alcohol) may berestricted from being assigned to jobswhere exposure to epichlorohydrincould occur and create additionalorgan stress. For all workers assignedto positions where epichlorohydrin

exposure could occur, annualexaminations with special attention tolung, liver, and kidney functions aresuggested.

Handling InstructionsAll employees involved in thehandling of epichlorohydrin shouldreceive instructions before they startworking with this substance. Theseinstructions should be about thespecific hazards of this chemical anddecontamination procedures in theevent of overexposure. Assistancewith worker training is availablefrom Dow.

Workers should be cautioned not tobreathe epichlorohydrin vapor.Odor does not give adequatewarning of an overexposure situation(see “Odor Threshold” on page 12).

Any symptoms of exposure toepichlorohydrin, such as eye orrespiratory irritation and skin rashes,should be reported immediately. Donot wear leather articles such asshoes, belts or watch bands, sinceleather cannot be decontaminated andcan increase localized burn potentialby holding the epichlorohydrinagainst the skin. Contaminated shoesor other articles of clothing should beremoved immediately.

Note: Be sure to physically destroyany such contaminated article toensure that it is not reused by otherindividuals.

Decontamination, First Aid,and Physician Notes

In the Event of Exposure• Remove the patient from the

exposure area immediately.

• Start thorough decontaminationprocedures at once.

• See a physician.

Decontamination• Eye exposure requires immediate

and thorough decontamination byirrigating the eye with low-pressurewater continuously for at least 15minutes.

• Skin contact with the liquid isirritating and capable of causingskin burns. Skin exposure requiresimmediate showering with copiousamounts of water for at least 15minutes. Use soap if available.

• Contaminated clothing should beremoved immediately, whileshowering. The clothing should bedestroyed and not be re-used.

• Leather goods (shoes, belts, andother) cannot be decontaminated.Contaminated leather goodsshould be physically destroyed toprevent accidental reuse.

First Aid• Remember, if respiratory distress

develops, move the affected personto fresh air. If the person is notbreathing, give artificialrespiration. If breathing is difficult,oxygen should be administered byqualified personnel.

• Do not induce vomiting. Call aphysician and/or transport to anemergency medical facility.

• Never give an unconscious personanything by mouth or attempt toinduce vomiting.

• In all cases, secure medicalattention at once.

Physician NotesSkin contact with the liquid isirritating and capable of causingdelayed skin burns. These mayescalate to deep second-degree burnswith little or no warning. If a burn ispresent, treat it as any thermal burnafter decontamination.

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Repeated skin contact even at a lowdose can lead to sensitization andallergic reactions.

If respiratory distress develops, restand oxygen administration may behelpful. Lung function should beassessed following a significant singleor intermittent inhalation exposure.Persons receiving significantexposures should be observed for 24-48 hours for signs of respiratorydistress. Any significantly exposedindividual should be monitored forliver and kidney function for at least60 days. Treatment is symptomaticand supportive if liver or kidneyinjury occurs. Chemical burns of theeye should be treated by a physicianexperienced in dealing with chemicaleye injuries, but only after immediateand adequate decontamination withwater.

If lavage is performed, endotrachealand/or esophageal control issuggested. Danger from lungaspiration must be weighed againsttoxicity when considering emptyingthe stomach. There is no specificantidote for epichlorohydrin.Provide supportive care. Treatmentshould be based on the judgment ofthe physician and the patient’sreactions.

Exposure LimitsGovernment exposure limits aresubject to periodic revision. Theinformation in Table 4 is given ingood faith and believed to be correctas of April 2006. Note: TheNational Institute for OccupationalSafety and Health (NIOSH) listingfor the vapor concentrationconsidered immediately dangerous tolife and health (IDLH) is 75 ppm for

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epichlorohydrin (see the NIOSHPocket Guide to Chemical Hazards,or visit their website at www.cdc.gov/niosh/npg/npg.html.

Further information on the healthand environmental effects ofepichlorohydrin can be reviewed onthe International Programme onChemical Safety (IPCS) INCHEMdocument: www.inchem.org/documents/ehc/ehc/ehc33.htm.

Exposure ControlAlthough epichlorohydrin has a veryhigh vapor pressure, it can becontrolled to maintain vaporconcentrations well belowoccupational exposure limits (seeTable 4). This should be achievedthrough properly designed, leak-tightproduct handling systems. Goodventilation is important; wheneverpossible, the epichlorohydrinhandling facilities should be locatedoutdoors to maximize naturalventilation. However, goodventilation cannot replace a closed,leak-tight system. Dow people haveextensive experience in this area andare prepared to help you evaluateproposed equipment designs. Wecan also provide information aboutthe equipment used in our operations(see “Storage and Equipment,” page31).

All aspects of the handling operation,from delivery through reaction todisposal, must be carefullyscrutinized for exposure potentials.Activities such as sampling shouldreceive particular attention.Measures that prevent exposuresshould be thoroughly explored.These include the use of vapor returnlines during product transfer, the drydisconnect style of fittings fortransfer hoses, automated samplingsystems, and the like.

Systems also must be designed toaccommodate safety showers andeye washes in the immediate area(less than 8 meters [26 feet] apart)where exposures are likely, such astruck or rail car off-loading stationsand locations where samples aretaken. Showers and eye washesshould be located so that workerswhose vision is impaired by anexposure can easily find them.

When respiratory protection isrequired for certain operations, usean approved full face air-purifyingrespirator or a positive-pressuresupplied-air respirator, depending onthe potential airborne concentration.If air-purifying respirator is used, itshould be fitted with a fresh canisterfor organic vapors or organic-vapor/acid-gas combinations.

Note: Used canisters should bedestroyed due to the poor odor-warning properties of epichloro-hydrin which make odor anunreliable indicator of chemicalbreakthrough.

For emergencies and other conditionsin which the exposure guideline maybe greatly exceeded, use an approvedpositive-pressure self-containedbreathing apparatus (SCBA) or apositive-pressure supplied-airrespirator with an auxiliary SCBA.

Tanks and reactors must not beentered until they have been washed,purged, and tested for the presence ofepichlorohydrin vapor (see proposedwashing and tank entry proceduresin section “Storage and Equipment,”page 31). Safe oxygen concentrations(19.5-23.5 percent) should bedemonstrated with an oxygenmeter test.

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Table 4: Regulatory Occupational Exposure Limits for Epichlorohydrin(1)

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Country 8-Hour TWA (ppm) 15-min STEL (ppm) Ceiling (ppm) NotesArgentina 0.5 A3; SkinAustria 3 12 Skin, Sensitizer, Carcinogen A2Australia 2 Skin, Carcinogen C2Belgium 2 Skin, CarcinogenBulgaria 2 Skin, Irritant, Allergenic, Carciogen C2Canada - Ontario 0.5 SkinCanada - Quebec 2 SkinCanada-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 SkinCanada-Manitoba 0.5China 0.26 0.53 SkinColumbia 0.5 Skin, A3Croatia 2 Skin, Irritant, Allergenic, Carciogen C2Czech Republic 0.26 0.53 Skin, SensitizerDenmark 0.5 SkinEstonia 0.5 1 Skin, Sensitizer, CarcinogenFinland 0.5 SkinFrance 2 Skin, C2Greece 2.5 5 SkinHong Kong 0.5 Skin; A3Hungary 0.5 Skin, SENIceland 0.5 Skin, Sensitizer, CarcinogenIndonesia 2 SkinIreland 0.5 1.5 Skin, Carcinogen C2Italy 0.5 SkinKorea 2Latvia 0.26 Allergenic, CarcinogenLithuania 0.5 1 Skin, Sensitizer, CarcinogenMalaysia 0.5 SkinMexico 2 5 SkinNetherlands 0.5New Zealand 0.5 1.5 Skin, Carcinogen A3Norway 0.5 Skin, Semsitizer, CarcinogenPeru 0.5 Skin, A3Philippines 5 SkinPoland 0.26Portugal 5 Skin, Carcinogen A3Romania 0.26 1.4 Skin, Potential CarcinogenRussia 0.3 Skin, AllRussian Federation 0.26 0.53 Skin, AllergenSerbia & Montenegro 2 Skin, CarcinogenSingapore 2Slovakia 3 Skin, C2 CarcinogenSlovenia 3 12 Skin, Carc2South Africa 0.5 1.5 Skin; ALARASpain 0.5 C2; posibilidad de sensibilizacion en contacto con la piel; SkinSweden 0.5 1 Skin, Carcinogen; SensitizerSwitzerland 2 Skin, Sensitizer, CarcinogenTaiwan 2 SkinUnited Kingdom 0.5 1.5U.S.A. - California 2 SkinU.S.A. - North Carolina 2 SkinU.S.A. Federal OSHA 5 SkinVenezuela 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

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Air MonitoringDue to its toxicity, high vaporpressure, and corrosive nature,epichlorohydrin can be safelyhandled in closed systems only.Because epichlorohydrin can beabsorbed through the skin in toxicquantities, it is particularly importantto avoid skin contact with vapor orliquid. All operations must bedesigned with engineering controls tominimize personnel exposure (see“Storage and Equipment,” page 31).Operations such as sampling, whichare often considered “open-system”operations, should also be designedto avoid exposure.

To ensure that epichlorohydrin iseffectively contained, a formal airmonitoring program should bedesigned and implemented by aqualified industrial hygienist. This isparticularly important forepichlorohydrin, which has poorodor-warning properties (see “OdorThreshold,” page 12). The odor-warning properties are not adequateindicators of an over exposurepotential.

The industrial hygienist shouldconsider all aspects of the operation,including work environment and jobtasks. When changes are made inprocedures or equipment, samplingshould be performed to verifycontainment. A Dow industrialhygienist can assist with airmonitoring and help determineexposure levels in your operation.Talk with a Dow representative formore information.

Personal ProtectiveEquipmentAll system designs should focus oneliminating the need for personalprotective equipment. However,personal protective equipment may berequired in certain operations, or inareas where exposure to vapor orliquid is possible, such as in the eventof a system failure. The selection anduse requirements of personalprotective equipment demand carefulmanagement consideration. Anoverall appraisal should be made ofthe plant operation, exposurepotentials, expected exposureduration, the specific activities beingperformed, and the training onpersonal protective equipment beingprovided to workers. This appraisalshould be performed by a qualifiedindustrial hygienist in conjunctionwith engineering, maintenance,supervisory, and management staff.An overall written plan to controlexposures should be developed. Theplan should identify the types ofapproved equipment (includingmanufacturer, make, and model); thetypes of protective equipment to usefor specific situations; the proceduresfor maintenance, cleaning, andstorage of the protective equipment;required training; and other issues.Issues to consider when selectingpersonal protective equipment andmanaging equipment programsinclude:

• Is there a practical way to reducethe expected exposure by changesin either equipment use orprocedures?

• Is the exposure likely to be at levelsabove the occupational exposurelimits (see Table 4)?

• Is the exposure likely to be of veryshort duration, after whichdecontamination can beimmediately accomplished, or will alengthy exposure occur?

• Is the exposure likely to occur onlyonce or twice per month as mightoccur in some unloadingoperations?

• Is single-use equipment desirable?

Note: The MSDS/SDS onepichlorohydrin suggests that airpurifying respirators, supplied air, orself-contained breathing apparatus(SCBA) be used depending onconditions when respiratoryprotection is required.

Protective ClothingEven well-engineered systems willrequire the use of personal protectiveclothing in the event of spills or otherpotential exposure situations.

In all operations involvingepichlorohydrin, and where employeeexposure is possible, workers shouldwear chemical workers’ goggles,safety hats, impervious boots, gloves,and outer clothing (full body-covering impervious suits). Trousersshould be worn outside the boots andsleeves should be taped to gloves(with tapered sleeve inserts betweensleeve and glove) to prevent contactof epichlorohydrin with the skin.

Clothing type, make, and materials ofconstruction should be carefullyevaluated using an “exposure controlmanagement” approach that evaluateseach exposure situation. For example,protective clothing for splashprotection (which is disposed of orimmediately cleaned after exposure)may not need to be as durable asprotective clothing for continuousexposure situations. Carefullyevaluate the data that is supplied byyour clothing manufacturer, payingparticular attention to the expectedclothing performance upon exposureto epichlorohydrin. Importantselection criteria are a highbreakthrough time and a lowpermeation rate (see Table 5).

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

It is important to recognize thehazards associated with eachmaterial choice. For example,leather is a hazard whencontaminated and should not bespecified for use. It can absorbepichlorohydrin and maintain a lowexposure level over a prolongedperiod of time, causing a severe burnbefore discomfort registers. Suchburns have been serious enough torequire skin grafts.

It is also necessary to set guidelinesfor decontaminating and destroyingprotective clothing. Leather articlesshould be destroyed to preventaccidental reuse.

Note: Personnel should be requiredto wear “work” clothes and to storethem separately from their “street”clothes. This allows the industriallaundry to handle and wash workclothes that could be chemicallycontaminated.

Impervious ClothingWhen choosing imperviousprotective clothing, the intrinsicbarrier properties like breakthroughtime and permeation rate are factorsto consider. Other factors that affectperformance include:

• Physical strength, abrasionresistance, or tear resistancerequired in specific use conditions;

• Thickness of the material;

• Fabrication technique (e.g. sealingof seams).

Dow suggests that customers obtaininformation from clothing andequipment suppliers about theperformance of their products ingiven situations and the barrierproperties to epichlorohydrin. Youmay also want to consult the DowMSDS/SDS.

Protective Equipment TrainingTraining of personnel on the use of protective equipment is the key to asuccessful program. Without a good understanding of the way the protectiveequipment works and its limitations, and the correct maintenance procedures,the expected protection factors are unlikely to be achieved. Specific issuessuch as the toxicity of epichlorohydrin vapors via the skin and the protectionrequired should be part of the training program. Training must also reviewthe proper way to wear, use, clean, and maintain each piece of equipment.

The use of respirators, for example, should require medical approval for theindividual and a fit-test to ensure effective protection. Training should bedocumented and reviewed with the employee(s) on a regular basis withretraining on a specified and annual basis.

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Table 5: Clothing Parameters

Item Considerations

Clothing, Gloves, Boots Butyl rubber appears to provide the best inherentbarrier properties.

Laminate constructions containing SARAN™ Resins orpolyvinyl alcohol can be designed to provide variouslevels of barrier.

Nitrile and neoprene rubber are penetrated morereadily.

Respiratory Protection Where low short-term exposures are anticipated, usefull face respirator with organic vapor or organicvapor/acid gas cartridges.

For unknown concentrations to those substantiallyabove the occupational exposure guide, use positive-pressure supplied air or self-contained, positive-pressure breathing apparatus (SCBA).

For emergency situations use self-contained, positive-pressure breathing apparatus.

Eye Protection Chemical workers’ goggles, if splashes ofepichlorohydrin 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 verylimited protection properties. These materials are readily penetrated and giveless protection.

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Figure 5: AZ-Armaturen Sampling System

Perhaps the best place to take the sample is from the line through which thevehicle will be off-loaded.

Note: The use of the sampling port provided within the dome on rail cars inNorth America will usually produce a non-representative sample because theline is often stagnant for long periods of time (the usual problems withsamples from the stagnant line are high color and non-volatile matter). If thesample port is to be used, sufficient purge to completely clear it will berequired.

Another approach to verifying the contents of a delivery vehicle is to samplethe atmosphere in the vehicle and test it for epichlorohydrin. The vent samplecan be taken in a purged sample bomb connected to the vehicle vent. If thesample is taken from the vapor return line, care must be taken to ensure thatthe sample is representative of the vehicle contents and not of the line.

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Sampling of DeliveryVehiclesSampling and analysis of the deliveryvehicle is the surest way to verify thatthe product is epichlorohydrin.

Sampling systems must be designedto avoid operator exposure. Manysuch systems are commerciallyavailable from specialty equipmentsuppliers; some suppliers will designa system specifically for yourpurposes. The systems vary fromsimple and low cost to very highlyautomated and expensive systems.Other systems of a less automatednature are also available that controlexposures, but require more operatortraining and care.

An example of a simple, but safe andeffective sampling system which iscommercially available is shown inFigure 5. It is available from AZ-Armaturen, www.az-armaturen.de.

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Venting of Delivery VehiclesAdequate venting of delivery vehiclesis an important safety practice duringoff-loading of epichlorohydrin.Inadequate venting can result in thecollapse of the vehicle. Points toconsider include:

• At normal off-loading rates, theindustry standard 3/4-inch vacuumrelief valve on delivery vehicles isnot sized to provide enough airflow to prevent catastrophic failureof the trailer barrel. Typically 15kPa (2-3 psi, 0.13 bar) negativepressure will cause failure;

• The collapse of the tank not onlyrepresents a serious safety issueand financial loss, but also canpotentially lead to a tear in the sidewall of the tank, which wouldlikely result in the unavoidable spillof the truck’s remaining contents;

• There are significant examples ofcatastrophic collapse of tankswhich were not adequately ventedduring off-loading (see Figure 6).

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

Customer ActionsDow recommends that customers take these actions:

• Evaluate the pressure drop at the maximum expected off-loading rate foreach vent system being used;

• Ensure that the vent system is designed to keep a positive pressure or nomore than 7 kPa (~1 psi) negative pressure on the delivery vehicle;

• Employ flow- and pressure- measurement devices on the vent line tied toshutdowns of the transfer equipment;

• Develop written procedures for off-loading, including a checklist of criticalactions to ensure venting.

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

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21

Although the chemical industry has one of the highest safety records, it isvery important to put an effective, well-developed plan in place to ensure

quick and effective response to emergencies. Emergency preparedness shouldconsider all aspects of emergency situations that may occur on the site, in thesurrounding community, or in the community at large.

This section describes a process for emergency planning and provides specificinformation about spills, fire-fighting, and associated waste disposal. Plansshould be developed with the assistance of local fire-fighters and communitygroups. Several resources are available from the International Council ofChemical Associations (ICCA), www.icca-chem.org; the American ChemistryCouncil (ACC), www.americanchemistry.com; and the European ChemicalIndustry 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.brDerivados 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

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Plan DevelopmentThe first step in emergency planning as defined by the ACC is crisismanagement planning. This begins with a definition of potential crises thatrequire planning, and then moves through a number of steps related toplanning, preparation, mobilization, response, recovery, and post-incidentfollow-up. The procedure should be comprehensive and consider all aspectsof potential emergencies, including warning alarms, evacuation assembly areasand escape routes, personnel accountability, communication vehicles, chain ofcommand, notification of authorities, dealing with the media, and otherimportant concerns. If your plant does not have a crisis management plan,one should be developed.


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If we assume that a generalemergency plan exists for yourfacility, the task of preparing for anew installation starts with a properdesign. Engineers should design thebulk storage and handling system toprevent hazardous conditions and toallow quick response if emergenciesoccur. For example, Dow requiresthe use of nitrogen padding onepichlorohydrin storage tanks toeliminate oxygen from the tank andthereby reduce the risk of fire. Anexcellent way to test a new design isto perform a process hazard analysis.For assistance, refer to a processsafety management publication, suchas that developed by the ACC. TheACC publication suggests methodsto identify, assess, control, andmanage hazards. As part of thehazard identification andmanagement process, it is alsoimportant to define safe operatingprocedures.

Helpful resources include:

• Crisis Management Planning forthe Chemical Industry, Manualand Videotape, 1992, Order No.022012, CMA.

• Site Emergency Response PlanningGuidebook, 1992, Order No.024041, CMA.

• Process Safety Management(Control of Acute Hazards), 1985,Order No. 047023, CMA.

• A Resource Guide forImplementing the Process SafetyCode of Management Practices,1990, Order No. 047024, CMA.

To obtain these resources, write to:American Chemistry Council1300 Wilson BoulevardArlington, VA 22209U.S.A.Phone: +1 (703) 741-5600

After completing both an overallcrisis management plan and aprocess hazard analysis, the nextlogical step is to develop writtenprocedures for responding topossible emergencies associated withthe new installation. These plansmust be carefully tied into theemergency plan and cover all of theaspects required in the overall plan.The procedures should also include aspecific plan for controlling theemergency. Procedures should coverall parameters, including fireextinguishers and similar equipment,emergency block valves, spillcontainment, personal protectiveequipment and clothing, and so on.All post-emergency procedures, suchas waste clean-up, waste disposal andequipment checks, should also beconsidered.

The plan should be tested in asimulated situation to ensure itseffectiveness in a real emergency.

The third step in developing anemergency plan involves communityinteraction. The plan should beintegrated into the community-wideemergency response plan. If yourcommunity does not have a plan thatintegrates industrial and civilemergencies, refer to the CommunityAwareness and Emergency Response(CAER) guide from the AmericanChemistry Council (ACC) or fromthe European Chemical IndustryCouncil (CEFIC). CAER is a

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chemical industry initiativesupported throughout the worldthrough Responsible Care®.

If your community does not have aplan that integrates industrial andcivil emergencies, refer to the sectionsCommunity Awareness andEmergency Response of theResponsible Care principles by theInternational Council of ChemicalAssociations (ICCA), www.icca-chem.org.

Transportation EmergencyWithin the framework ofResponsible Care, Dow and itscarriers make every effort totransport goods to and from itsmanufacturing sites and storagelocations safely and in fullaccordance with relevant regulationsand codes of practice. In the event ofan incident, the chemical industrywill provide information, practicalhelp and, if necessary and possible,appropriate equipment to thecompetent emergency authorities inorder to minimize any adverseeffects.

® Responsible Care is a service mark of the American Chemistry Council in the United States

CMA (Chemical Manufacturers Association) has beenrenamed ACC (American Chemistry Council).

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North AmericaCHEMTREC (CHEMicalTRansportation Emergency Center),www.chemtrec.com, is committed toproviding emergency responsepersonnel, law enforcement agencies,and other interested persons withinformation necessary to bettermitigate emergencies associated withhazardous materials.

EuropeICE (International ChemicalEnvironment, European EmergencyResponse Network) www.cefic.org/activities/logistics/ice/ice-guide.htm, isa cooperative program betweenchemical companies to preventchemical transport incidents and torespond effectively if and when theydo occur.

Other CountriesPlease refer to country-specificemergency organizations (see Table 6).

Fire-Fighting Guidelines

Fire HazardsEpichlorohydrin is a flammable liquidand its vapor forms explosivemixtures with air.

Although the lower limit for oxygenconcentration for epichlorohydrinflammability is 11.6 percent, Dowrequires the concentration to bebelow 8 percent as a safety factor.

Hazardous Combustion ProductsDuring a fire, smoke may contain theoriginal material in addition tocombustion products of varyingcomposition which may be toxic and/or irritating. Combustion productsmay include and are not limited to:Hydrogen chloride. Carbonmonoxide. Carbon dioxide.

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Table 7: Flammability Limits for Epichlorohydrin

Flammability Limits LFL UFLLower 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 toa source of ignition and then flash back. The material is moderately soluble inwater (6.6 percent at 20˚C/68˚F).

Fire-Fighting MethodsUse water fog, dry chemical, alcohol foam, or carbon dioxide when fightingfire. Use water to keep fire-exposed containers cool. If a leak or spill has notignited, use water fog to disperse the vapors and to provide protection forworkers attempting to stop a leak. Water fog may be used to flush spills awayfrom potential ignition sources.

Wear a positive-pressure, self-contained breathing apparatus if contact withthe vapors is possible; wear full protective clothing (see “Health, Safety, andHandling” on page 12).

For more information, review the local and country codes for fire protectionsuch as the National Fire Protection Association (NFPA), www.nfpa.org, theEuropean EN standards or the global International Electrical Councilstandards (IEC).

Table 8: Fire Protection Standards

Item North America Europe Pacific Worldwide

Flammable and NFPA No. 30 EN standards Country-Combustible Liquids specific

standards

Electrical Codes NFPA No. 70 EN standards Country- IEC standardsspecificstandards

Protection Codes NFPA No. 780 EN standards Country- IEC standardsspecificstandards

–

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Spill Clean-Up

Degradation in the EnvironmentEpichlorohydrin is slightly toxic toaquatic organisms and moderatelytoxic to algae. It may also bemoderately toxic to mammalianwildlife.

Epichlorohydrin is a mobile, volatileliquid with a water solubility ofapproximately 6.6 percent (66 g/l).Epichlorohydrin hydrolyzes in distilledwater at a rate of 9.75 x 10-7 s-1, whichcorresponds to 50 percent hydrolysis in8.2 days (see Mabey and Mill resourcebelow).

It also reacts with other nucleophilessuch as chloride or hydroxide, whichcould lead to a more rapidhydrolysis.

Dow studies, in addition to otherwork by W. Mabey, T. Mill, A.L.Bridie, and S. Sasaki (see resourcesbelow), indicate that biodegradationis a major environmental processwith 5-day Biological OxygenDemand (BOD) values of 18 percent(Dow) and 14 percent (acclimated;Bridie). Biodegradation continueswith BOD values of 43 percent and53 percent after 10 and 20 days,respectively (Dow) and issignificantly degradable in theJapanese Ministry of InternationalTrade and Industry test (Sasaki).Biodegradation can also take place insurface soil. The high watersolubility and mobility makes itpossible for epichlorohydrin to enterthe ground water wherebiodegradation is expected tocontinue, but at a slower pace. Thehydrolysis of epichlorohydrin willprevent it from being a ground waterpollutant other than immediatelyafter a large spill. In the aquaticenvironment, epichlorohydrin willhydrolyze, biodegrade, and volatilize.

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In a wastewater treatment system,the same processes will take place,with hydrolysis playing a minor roledue to the short residence time.

Overall, epichlorohydrin is relativelyunstable in the air and water.However, when spilled, it may exerta toxic action before hydrolysis.Epichlorohydrin is inherentlybiodegradable and thebioconcentration potential is low.Contamination of soil and watershould be minimized by spillcontainment and removal, wheneverpossible.

For more information, review theDow MSDS/SDS or the followingstudies:

• Critical Review of Hydrolysis ofOrganic Compounds in WaterUnder Environmental Conditions,W. Mabey and T. Mill, J Phys.Chem. Ref. Data 7, 383-415(1978); quoting J.N. Bronsted andM. Kilpatrick, J Amer. Chem. Soc.,51, 428 (1929).

• BOD and COD (ChemicalOxygen Demand) of SomePetrochemicals, A.L. Bridie, C.J.M.Wolff, and M. Winter, Water Res.,13, 627-630 (1979).

• Aquatic Pollutants: Transformationand Environmental Effects,S. Sasaki, O. Hytzinger et.al.eds.,Pergamon, Oxford pp. 283-298,(1978).

AbsorbentsDry sand or ground polypropylenematerials are suitable absorbents forepichlorohydrin spills. Theadvantage of polypropylene-basedabsorbents lies in their ability to beincinerated without creating a largeash loading on the incinerator.

Two specific polypropyleneabsorbents tested by Dow are Haz-Mat Pig and Polysorb from New PigCorp., One Pork Ave., Tipton, PA16684-0304, U.S.A., www.newpig.com; and Lab Safety Supply Inc.,P.O. Box 1368, Janesville, WI53547-1368, U.S.A.

Clay-based absorbents should not beused since they react with theepichlorohydrin resulting in theevolution of heat. Heat from thisreaction can result in spontaneouscombustion since auto-ignitiontemperatures can be reached.

Other absorbents may be suitable,but should be tested prior to use forreactivity with epichlorohydrin.

For large spills, clean-up is often besthandled with a vacuum truck. If thisapproach is used, the truck should bepadded with an inert gas beforevacuuming the spill. Care should betaken not to introduce air into thetruck as liquid is vacuumed. Thiscould create an explosive atmospherein the vacuum truck. Consider thatthe vent of the vacuum truck willemit significant amounts ofepichlorohydrin vapor, which couldcause additional hazards(environmental or health).

The possibility of a two-phase watermix must be considered; the hazardcaused by a reaction withepichlorohydrin can occur over time.

Note: Suppliers and their productsidentified in this Manual are referredto in good faith, but no endorsementis made. It is the customer’sresponsibility to research availablesuppliers and make the appropriateselection.

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Waste DisposalEpichlorohydrin is classified as ahazardous waste in any part of theworld. The relevant country-specificMSDS/SDS should be consulted forspecific government requirementsrelated to waste disposal. Customersare advised to check their localapplicable government requirements.

Several methods of disposal areavailable, including incineration, bio-treatment, and chemical conversion.Applicable government requirementsmust be considered prior to selecting amethod. Final disposal methodsshould be discussed with localauthorities whenever possible.

All applicable governmentrequirements regarding health,environment, and waste disposal mustbe observed. Contact Dow foradditional information.

All quantities of epichlorohydrin - orwaste material contaminated withepichlorohydrin - should be removedto an approved industrial wastedisposal area. If epichlorohydrin is tobe incinerated, only an approvedincinerator suitable for handlingchlorinated hydrocarbons can beused. During incineration, hydrogenchloride is produced and must bescrubbed out of the gas from theincinerator.

Water contaminated withepichlorohydrin should be drained toa controlled area. This contaminatedwater should be treated at anapproved water treatment facility.

When a problem arises as a result of amajor spill or equipment rupture,only properly protected and trainedpersonnel should remain in the areato supervise response and cleanup.

HydrolysisThe alkaline hydrolysis of dilute water solutions of epichlorohydrin to glycerinecan, under certain circumstances, be a desirable way to handle very smallquantities 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-lifeapproximately 15 minutes).

Note: The hydrolysis reactions of epichlorohydrin generate heat and apressure build-up is a serious concern if the reaction is done in a containedsystem. Under alkaline conditions, the hydrolysis of epichlorohydrin proceedsto glycerine through an intermediate: glycidol. 2,3-Epoxy-propan-1-ol (notethat glycidol is also toxic). The reaction rate is relatively slow at roomtemperature and can take days or weeks, depending upon circumstances, toproceed completely to the final product, glycerine. The reaction rate increasesat elevated temperature. Treating large amounts (>100kg) of epichlorohydrinwith dilute alkali at ambient temperatures with subsquent heating can lead toan uncontrollable polymerization with excessive heat generation.

If hydrolysis is considered, tests should be run to determine the exact chemicalmake-up of the resulting mixture before proceeding with disposal. Largeamounts of epichlorohydrin should be disposed of in an incinerator.

Note: Do not use sodium carbonate or other alkali as an absorbent for spilledepichlorohydrin.

If removal of trace quantities of epichlorohydrin from equipment is theobjective, the use of low- or medium-pressure steam should be considered asthe first means to react it.

Hydrolysis at ambient temperatures at neutral or acid pH is not suggestedbecause the reaction beyond the initially-formed chlorohydrins proceedsslowly.

Contact your Dow representative if you wish additional information orassistance.

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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-loadDOW™ Epichlorohydrin.

Note: Dow will not make deliveries to sites with which we are not familiar orare not assured that personnel are capable of safe unloading and storage. Ingeneral, this means that Dow will not deliver to a site that has not been visitedand reviewed by a Dow representative. Upon request, Dow technicalpersonnel will review the engineering plans of a proposed new facility andprovide feedback and suggestions.

It is important to carefully instruct all personnel involved in the handling ofepichlorohydrin (including unloading operators) on the hazardous propertiesof this material. Because the degree of hazard in handling or unloadingepichlorohydrin varies from one operation to another, individual situationsshould 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 thatthe person requesting the sample is aware of the material’s hazards and canhandle 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 thestorage tank. The vehicles in North America are also designed with a dry breakfitting 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 breakfittings are very effective at reducing the spillage during connection anddisconnection to only a few droplets of fluid. The dry break feature requiresthat 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


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Parts shown are:

• 1676 AN-SS-20 2-inch (5.08-cm) stainless steel adapter with femaleNational Pipe Thread and Chemraz seals

• 1773 D-SS-20 2-inch (5.08-cm) stainless steel coupler with femaleNational Pipe Thread and Chemraz seals

Parts not shown are:

• 1676 AN-SS-15 1-1/2-inch (3.81-cm) stainless steel adapter withfemale National Pipe Thread and Chemraz seals

• 1773 D-SS-15 1-1/2-inch (3.81-cm) stainless steel coupler withfemale 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 ShipmentsFor road truck deliveries in North America, Dow uses a dedicated fleet oftrucks owned and managed by a single carrier. This carrier employs onlydrivers who have received extensive training about the properties and hazardsof epichlorohydrin and the procedure in which delivery equipment must behandled for a safe, spill-free delivery. These drivers can be a very usefulresource to assist your operating personnel with trouble-free transfers.

In Europe and other regions, the truck quantity deliveries are made in dedicatedintermodal containers (“ISO-containers”, 23 metric tons, volume 25,000 liters)by a single carrier. A program of carrier appraisal and driver training is also inplace.

ISO-containers can be unloaded either from the top or from the bottom. Thestandard 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 BSP-coupling.

To minimize personnel exposure to epichlorohydrin, Dow requires customersto use their own dedicated hose permanently attached to their pumpingsystem. For this reason, Dow does not supply hoses or truck pumps.

Dow Product Stewards can provide product safety training for youremployees, and will also attend your first delivery. Talk to your Dowrepresentative or call your nearest Dow location for assistance.

Rail ShipmentsDow also ships product in a dedicated fleet of rail cars. These cars are 20,000gallon (80 metric tons) pressure cars set up for top off-loading only. In NorthAmerica, these cars are all fitted with dry break fittings for both liquid andvapor 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) andare designed for top and bottom discharge. The sizes of the connection flangesin Europe are DN100 for liquid and DN50/DN80 for vapor.

Rail cars are not used in regions other than North America and Europe.

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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: FlangeBottom: 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

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Delivery ChecklistThe following checklist is designed tohelp you prepare for a first delivery ofeither a bulk truck, ISO-container ora rail car to a new facility. Forspecific information about hardware,see “Storage and Equipment” onpage 31, or talk to your Dow ProductSteward.

• Has a Dow Product Steward visitedyour facility and reviewed yourbulk epichlorohydrin handling andstorage facility? Has Dow agreed todeliver to your facility?

Note: Dow will not deliver to afacility without performing an on-sitereview to verify that it meets ourrequired practices for bulk delivery.

• Have you arranged for a DowProduct Steward to attend the firstdelivery?

• Was the off-loading piping andvalve system pressure-tested toensure that it is leak-free? If waterwas used for the pressure test, howwas the system dried? Was the off-loading pump tested with liquidafter installation?

Note: Any water in the system willcreate quality and safety problems.

• Is a written off-loading procedureavailable to employees?

• Was the procedure reviewed by theoff-loading operator? Will theoperator use it as a checklist for off-loading?

• How will the vehicle be managedfor spill containment? Are therevalve position changes required tosecure the containment system? Ifso, are they described in the off-loading procedure?

Note: Dow suggests a spill-containment volume great enough tohold the entire contents of the vehiclescheduled for off-loading.

• Are spotting, chocking, and brakesecurement requirements clearlyidentified?

Note: For trucks, the driver shouldhave clear instructions to surrenderthe keys and leave the truck cab.

• Is the operator required to use all ofthe appropriate protective gear(e.g., impervious suit, imperviousrubber footwear and gloves, hardhat, approved respirator) before off-loading?

• Are the safety shower and eye washstations immediately accessible inthe off-loading area? Are they testedbefore any connections are made tothe vehicle?

• Is the off-loading area cordoned offor barricaded to keep unauthorizedpersonnel and vehicles out?

Note: Are warning signs typicallyused for the mode of transport usedto secure the unloading area

• Has the vehicle’s electrical groundbeen verified?

• Has the off-loading operatorreceived training on the hazards ofthe product and reviewed currentMSDS/SDS?

• Has the driver received appropriatetraining and instructions on thespecific handling by the customer, ifthe driver is supposed to assistduring offloading?

Dow can assist to help manage thetraining with the carrier personnel.

• Will a check be made of thevehicle’s number, seals, and productidentification tag (on the off-loading line) to verify the productagainst both the delivery note andCertificate of Analysis?

Note: Product stencils / label andaccompanying documents on rail carsalso should be checked.

• Will a sample be drawn andanalyzed prior to off-loading?

Note: Dow suggests sampling andtesting to positively confirm theproduct in the vehicle as epichloro-hydrin (see “Sampling of DeliveryVehicles,” page 19).

• What precautions will be taken toavoid personnel exposure? Ispersonnel protective equipmentadequate?

• Are all lines and vessels properlylabeled and identified?

• If connections have to be made onthe top of the transport vehicle, isprotection against falls adequate?

• Was the oxygen level in the storagetank checked and verified to bebelow 8 percent?

• Are all terminal lines plugged(blinded) to prevent spills from anaccidental valve opening (e.g.,sampling and blow-down lines)?

• Are a fire extinguisher and suitableabsorbent material available in theimmediate area?

• Is there a communication link to thecontrol room? How will it bemaintained during off-loading?

• Have calculations been made andconfirmed to ensure that the loadwill fit into the available tankspace?

• How will the transfer of the loadinto the tank be monitored to verifymovement of product when thepump is started and to ensure thatthe product is going to the correctlocation? How will the movementof vapors through the vapor returnline to the vehicle be establishedand verified?

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Note: Truck trailers and Intermodalcontainers are particularlysusceptible to damage from negativepressure and will collapse if notvented. The vehicle safety systemmay provide an audible warningalarm as it starts to relieve and suckair into the trailer. At any sign ofsafety valve relief, the transfer shouldbe stopped immediately.

• Is the off-loading procedure clearabout the location and size of theliquid and vapor lines?

• When the dry disconnects areconnected, are they locked in placeby securing the arms in a closedposition?

• Before opening the valves on boththe vent and liquid sides, will acareful check for leaks be made?

• Are gas detectors installed atstrategic points to sound an alarmif a leak occurs?

• At what pressure is the storagetank?

Note: If it is at a pressure thatexceeds the vehicle safety system, thepressure relief valve will open and avapor cloud will be released.Pressure relief valves in NorthAmerica are typically set to 25 psig(trailers), and 75 psig (rail cars). InEurope, the safety pressure setting is400 kPa (4 bar) with initial openingat 300 kPa (3 bar) for both rail carsand Intermodal containers.

• After the transfer is initiated, is theoperator required to stay withinsight of the connections until theload is completely transferred? If arail car is involved, how will it bemonitored?

Note: This is required by U.S. lawfor tank trucks and rail cars.

• How will the operator know whenthe vehicle is empty so that thepump can be shut down as soon asit loses suction?

• If the liquid line will be blown clearprior to disconnection, how willthe nitrogen be regulated to notexceed the pressure at which thevehicle’s safety system begins torelieve? Are steps defined andfollowed if a blow-down isperformed?

Note: Hoses should not be lefthydraulically full.

• What procedure will be used toensure all liquid and vapor returnlines on the car and piping systemare correctly blown clear, de-pressured, and blocked to securethe system and the delivery vehicle?

Note: Specially trained and licensedworkers are required to accomplishthe task of rail car and trucksecurement.

• When disconnection of the drybreak fitting occurs, does theprocedure require the use ofappropriate protective gear?

• Will the hoses be secured to keepthem clean and contamination-freefor the next load?

• Will the operator ensure that thefall restraint, chocks, ground strap,and barricades are removed andthat the placards are reversed andderail and warning signs areremoved before releasing a rail car?

• Rail cars and European Intermodalcontainers also have top dischargelines. Establishing pump suctionrequires specific operatingprocedures. How will this bemanaged?

Note: The procedures must eitherutilize the pressure in the car uponarrival (North America 5 to 9 psi). InEurope, the overpressure in the carsand containers on the shipping pointwill be approximately 30 kPa (0.3bar). Alternatively, the pressure canbe provided by an inert gas(nitrogen) through the gas phaseconnection of the delivery vehicle topush the product out of the car toflood the pump suction.

Note: The customer should have acheck valve in the inert gas line toavoid contamination and back flowinto the inert gas system.

• What mechanism is in place thatallows the operator to factor anylearning experiences into the nextoff-loading experience - to contin-uously improve performance?

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Storage and Equipment

The guidelines in this section of the Epichlorohydrin Product StewardshipManual are general and should be used with information from tank and

equipment manufacturers and professional engineering firms. Dow ProductStewards can help you evaluate engineering suggestions and can assist youwith ecological and product safety considerations.

Dow can provide technical assistance during equipment installation, reviewyour site prior to the first delivery, and assist your staff during that delivery toensure that minimum requirements are met for a safe, exposure-free delivery.We can also review customer-supplied schematics of storage and off-loadingequipment, and make suggestions for improvement.

Contact your Dow representative for information, or call the Dow locationnearest you.

Materials of ConstructionCarbon steel is satisfactory for the transport and storage of epichlorohydrin.Steel is used for storage tanks, lines, valves, and fittings, and tank cars. Tanktrucks are usually of stainless steel construction. If the material will be storedlonger than 12 months, color may develop. In such cases, stainless steel tankconstruction should be considered.

Cast iron is not recommended for auxiliary equipment, such as pumps andvalves, due to its brittleness.

Hazardous MaterialsWarning: The following materials can create varying degrees of hazard due totheir incompatibility with epichlorohydrin.

Aluminum, Magnesium, Copper, Tin, Zinc, Lead, and Their AlloysThese metals should not be used in systems containing epichlorohydrinbecause of their potential to initiate a violent polymerization reaction.Similarly, alloys of these metals (such as bronzes and some brasscompositions) should be avoided.

CatalystsEpichlorohydrin may polymerize spontaneously and with explosive violencein the presence of catalysts such as acids, bases, and compounds having labilehydrogens (Lewis acids). Back-flow into storage vessels or lines must beprevented.

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Bulk Handling ChecklistSome specific engineering design andprocedural/operational consider-ations for off-loading and storagesystems include:

• Spill containment for the storagetank and for vehicles that will beoff-loaded.

Note: A volume sufficient to holdthe entire contents of the tank andvehicle is suggested.

• A nitrogen pad on the storage tankto ensure that the tank contentsremain at less than 8 percentoxygen.

• Isolation of the epichlorohydrinstorage tank from storage areascontaining materials reactive withepichlorohydrin.

• Fire protection meeting localstandards.

• Over-pressure of the storage tankunder normal and worst caseconditions (usually fire).

• Overfill of the storage tank (e.g.level measurement, alarms andshut-down of unloading pump).

• Temperature measurement on thetank and pump.

• Oxygen measurement, particularlywith a new facility prior to firstdelivery.

• Pump shut-down under abnormalconditions (e.g. deadhead, tankhigh level, low flow, high pumptemperature, and lack of flow invent back to vehicle).

• Exposure of workers and theenvironment during connection ofthe transfer.

Note: Dow suggests using dedicatedequipment permanently attached totransfer piping.

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• Fittings to match those on thedelivery vehicle.

• Use of a customer-supplied pumpwith a closed-loop vapor returnline. This is suggested over the useof nitrogen to pressure off theproduct with vapor abatement onthe storage tank.

• If a closed-loop vapor return is notused, make sure that sufficientnitrogen is available and utilized toensure that the oxygen level in thevehicle being off-loaded ispermanently maintained at lessthan 8 percent.

Note: Consider the allowedmaximum pressure of the deliveryvehicle. Dow prefers that deliveryvehicles are returned with anoverpressure of not more than 100kPa (1.0 bar, ~15 psig)

• A sampling system and testingmechanism to confirm the productin the vehicle as epichlorohydrin(see Handling and SamplingGuidelines in “Health, Safety, andHandling,” page 12).

• Blow-down of the unloading lineprior to its disconnection from thedelivery vehicle.

Note: It is suggested that nitrogen beregulated to less than 100 kPa (1.0bar, ~15 psig).

• Prevention of back flow of anystreams into the storage tank.

• Plugging of line ends to preventspills from an accidental valveopening (e.g. sampling and blow-down lines).

• Electrical grounding for storagetank, delivery vehicle, and off-loading system.

• Safety shower and eye bathimmediately accessible to the off-loading area, and tested prior tobeginning the transfer.

• Waste disposal practices to meet allregulations.

• Tank and line labeling to indicateepichlorohydrin.

Note: The use of NFPA symbols(Health=3, Flammability=3,Reactivity=2) on the tank aresuggested in North America.

• Flammable gas detection aroundthe tank and other potential spillareas.

• Process hazard analysis (see also“Emergency Preparedness,” page21).

• Emergency preparedness.

Note: It is suggested that a PlantEmergency Plan be coordinated withthe overall community emergencyplan (see “Emergency Preparedness,”page 21).

Also refer to Figures 11 and 12 forschematics of a typical bulk storageand tank truck off-loading system,and a typical rail car off-loadingsystem.

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

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11

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Note: Label Lines for Content

Tank Truck

Deluge/Foam

To Process

Low Point Drain

Centrfugal PumpGround SlopeSpillContainment Wall

Epichlorohydrin

Access Platform

Depad toVent Scubber

Flex Hose

Valve or Vapor Line

Dry Disconnect

Fittings To SampleSystem

Safety shower & Eyewash

To DelugeSystem

Vent toSafe Area

FoamStor.

FireMonitor

FireExt.

Nitrogen

Nitrogen

PCV

PCV

EBV

PCV

ERVERV

VRV

HLA

FIFT

LI 33

2LT

PIPT

PIPT

FIFT

FIFT

GASDET.

HLSHLA

TITT

TITT Vehicle Spill

Containment(Remote)

1 1/

2" V

apor

2" Liquid

Ground Absorbent

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Figure 12: Typical Rail Car Top Off-Loading System for Epichlorohydrin

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EpichlorohydrinRail Car

Locate Derail at Least50' 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

32" Liquid

Safety Shower& Eyewash

PI

PCV

Customer AccessPlatform

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

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Figure 13: Unloading a Bulk Tank Truck

A Dow customer demonstrates a typical hook-up of a bulk tank truck withdry disconnects

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Figure 14: Typical Intermodal ISO Container

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

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Tank StorageThe suggested storage tank forepichlorohydrin is an AmericanPetroleum Industry (API) Type 620tank that uses a nitrogen pad of 40-70 kPa (6-10 psi, 0.4-0.7 bar).American Society of MechanicalEngineers (ASME) code vessels withhigher pressure ratings are alsoexcellent choices.

A European design standard fortanks and vessels is EN 14015.

Note: The vapor pressure ofepichlorohydrin is low enough thatan atmospheric pressure tank (suchas API Type 650 tank) could be used,but would probably not be the bestchoice due to the difficulty inmaintaining a positive nitrogenpressure on the tank without ventingepichlorohydrin vapors. Such asystem would require specialconsiderations to ensure that thevapors are appropriately scrubbedand did not pose an exposurepotential for workers.

In any case, the tank should bedesigned, constructed, installed, andused in accordance with theappropriate national codes forepichlorohydrin storage. NationalFire Protection Association (NFPA)codes are appropriate for NorthAmerica. The tank should also meetall local codes and ordinances.

Carbon steel tanks are normallysuitable for storage of epichloro-hydrin. If the material will be storedfor more than 12 months, however,stainless steel construction should beconsidered to prevent discoloration.

Storage tanks must be constructed torelieve excessive pressure in case offire. This can be achieved throughpressure relief valves or emergencyrelief vents of adequate capacity torelieve tank over-pressure and toprevent rupture.

Note: Open vents should not beused to avoid emissions to theatmosphere due to breathing of thetank.

Storage tanks must be diked orotherwise contained. Positivedrainage to an impounding area thatavoids exposure to personnel orequipment is suggested. Shell-to-shell separations of tanks should bebased on loss prevention principles.The minimum distance from the tankshell to the dike wall should be set toprevent trajectories of escaping liquid(from possible leaks) from clearingthe dike. Dikes should be designedwith adequate volume to hold themaximum foreseeable spill withadditional volume to contain delugewater and foam from extinguishingsystems. Management of waterduring an emergency situation mustbe incorporated in the design.

Note: Careful design by a qualifiedengineering service is required toensure an appropriately sizedcontainment design to manage allpotential emergencies.

Water spray rings around the tankare suggested to provide a waterdeluge when fighting fire (it alsoprovides additional cooling for thetank in a fire situation). These samespray rings can be used to deliverfoam by injecting the foaming agentinto the water supply. Fire-fightingmonitors around the storage facilityshould be considered as part of thedesign. Again, the fire protectionsystem must be carefully designed byengineering experts who specialize inthis service.

The storage tank should be equippedwith a nitrogen gas padding system.An effective gas padding system canbe created using a pressure controlvalve on the nitrogen supply line tomaintain a minimum pressure (pad).It can also feature a maximumpressure (de-pad) pressure relief valveon top of the storage tank to preventover-pressure. Such a system will notonly provide a minimum positivepressure and protect againstexcessive pressure build-up, but alsowill conserve nitrogen. The nitrogenpad will preclude air from enteringthe system. Air contains moisturethat can react with epichlorohydrinand/or its impurities to form othercompounds which can be reactive orcatalytic in nature.

Note: Tank vents should be handledin a manner that prevents personnelexposure and is acceptable from anemissions standpoint.

Dow suggests that vented material behandled by vapor return to thedelivery vehicle. Tank breathingvapors are preferably incinerated in awell-designed incineration unit.Alternatively, the breathing vaporscan be absorbed with a causticscrubber, an absorption unit, or bycondensation. Any of these systemswill require a careful design by aqualified engineering service.

Mechanical pressure vacuum reliefdevices should also be provided tosatisfy the relief requirements ofcodes and standards applicable toinstallation (e.g., NFPA in NorthAmerica, EN standards in Europe).

Additional equipment should includeadequate manholes or entrancepassages that allow workers to cleanor repair tanks, a bottom drain tocompletely empty tanks whennecessary, and two independent levelmeasurement devices.

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Also, be sure that the tank and allmetal piping and pumps areelectrically grounded.

See Figures 11 and 12 for furtherinstrumentation and controlsuggestions.

Because epichlorohydrin mayhomopolymerize spontaneously andwith explosive force (100 kJ/mol,24.3 kcal/mol at 25˚C/77˚F) in thepresence of catalysts such as acids,bases, and compounds having labilehydrogens, it should be stored onlyin tanks that have been thoroughlycleaned and dried, e.g., buffed andsteamed, water-washed, and driedwith an inert gas, such as nitrogen(See section Tank CleaningProcedures).

Note: Combining epichlorohydrinand water can form a particularlyhazardous two-phase mixture (see“Properties and Uses,” page 6, forsolubility information). Over time,an exothermic reaction will start atthe interface which can generateenough heat to create pressure build-up in the vessel. Such mixtures mustbe disposed of promptly (see “EmergencyPreparedness,” page 21, for disposalinformation).

Great care must be taken to preventback flow or other inadvertentaddition of reactive materials to thestorage tanks. Prior to start-up, aprocess hazards analysis should beperformed to identify flow,temperature, pressure, equipmentfailure, operating errors, or otherconditions that could create anunexpected hazard (see “EmergencyPreparedness,” page 21).

Tank Cleaning ProceduresThe following procedure to cleantanks containing epichlorohydrin issuggested.

Note: Tank cleaning will requirepersonnel to enter the epichloro-hydrin storage vessel. To ensure thisis done safely, a detailed vessel entryprocedure that includes the testing ofthe environment in the tank shouldbe developed by qualified personnel.The procedure should be used andsigned by the responsible people,including the operator and tradesperson.

1. Use a pump to remove theepichlorohydrin from the tankuntil the pump loses prime.

2. Blind or remove all process pipingfrom the tank to avoid accidentalflows into the tank during theclean-up or tank entryprocedures.

3. Fill the tank at least half way withwater to remove any liquidpockets of epichlorohydrin. If thetank is too large or disposal ofwater is a problem, this step maybe omitted if the following Step 4is performed.

4. Water-wash for at least 8 hoursusing some form of multi-directional spray washing nozzle(e.g., the type used to wash tanktrucks or cars). Alternatively a10 percent Sodium hydroxidesolution can be used for about1 hour.

Note: This step is essential to tankcleaning; it greatly minimizes theamount of epichlorohydrin thatcould vent out in the following steps.

5. The remaining steps of thecleaning procedure are dependentupon the type of lining andexterior paint on the tank, andthe amount of deposits in thetank itself. These steps arecategorized as low-, medium-,and high-temperature cleaningprocedures. Follow Steps 1-4above, then proceed with thesteps described in the low-,medium-, or high-temperaturecategories.

Note: It is very important to use thefollowing cleaning proceduresregarding proper temperature limitson linings, exterior paints, andinsulation, since most manufacturerísguidelines do not have large safetyfactors. Linings and exterior paintsare very easily damaged by heat, andare expensive to repair.

Note: All water and epichlorohydrinmixtures must be contained anddisposed of as required byregulations (see “Waste Disposal,”page 25).

Low-Temperature CleaningThis type of procedure should beused for any tank that is lined,insulated, or painted with a materialthat is not capable of withstandingabove-ambient temperatures.

5a. Continue washing with themultidirectional spray nozzle set-up for an additional 12-16 hours.Open all drains on the tank.

5b. Connect an air-moving devicecapable of quickly turning overthe air volume in the tank.

5c. Test the tank environment forflammability, toxicity, andoxygen content. See under tankentry below.

5d. If the air test results show that itis not acceptable to enter,continue to wash the tank untilacceptable limits are reached.

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Medium-Temperature CleaningThis type of procedure is appropriatefor tanks that are lined, insulated, orpainted with a material capable ofwithstanding boiling water up to100˚C (212˚F), but not directsteaming.

5a. Open a vent valve at the top ofthe tank and fill the tank 80percent with water.

5b. Connect a steam hose to thebottom of the tank and introducesteam. Raise the watertemperature to boiling, then boilthe water for 6 to 8 hours. Becareful not to overboil, causingwater to exit the vent valve.

5c. Drain the water and purge thetank to ambient temperaturewith an air-moving device.

5d. Test the tank environment forsafe levels of flammability,toxicity, and oxygen. See undertank entry below.

5e. Repeat the boiling procedure ifthe air tests are unacceptable.Continue until acceptable limitsare reached.

High-Temperature CleaningUse this procedure for any tank thatis lined, insulated, or painted with amaterial capable of withstandingtemperatures up to 250˚C (482˚F).

5a. Open the vent and drain valveson the tank.

5b. Connect a low pressure (240kPa, 2.4 bar, ~35 psig or less)steam hose to the tank and flowsteam into it, making sure thatthe tank does not over-pressure.

5c. Increase the tank temperature to95˚C (203˚F) for 2 to 4 hours, oruntil no detectable epichloro-hydrin is remaining.

5d. Turn off the steam, connect an air-moving device, and cool the tank downto 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 furthersteamed until acceptable limits are reached.

Tank/Vessel EntryA written tank entry procedure should be in place. This procedure shouldregulate which tests have to be done prior to the approval of tank entry by aresponsible person. Required tests are oxygen content, flammability,detectable epichlorohydrin and electrical safety. Suggested additional tests aretemperature (especially after steaming). The procedure should further regulatewho gives the final approval for tank entry. Persons entering tanks shouldwear 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 betested for safe levels of those compounds, too. Check with the relevantmanufacturer for acceptable levels of entry.

RecommissioningBefore filling a tank with epichlorohydrin, follow these steps:

1. Pad and de-pad with nitrogen until the measured oxygen content is 8percent or less.

2. The tank must be dry. This can be assured by making a dew pointdetermination on a representative sample of a nitrogen purge flow fromthe tank. A dew point of less than -40˚C (-40˚F), as measured by a dew-point apparatus, is used at Dow as the acceptable level of dryness.

3. Ensure that all safety and other systems are reinstalled and tested to verifycorrect operation.

Note: Nitrogen Hazard! A number of fatalities have recently been caused bypersons entering into areas and equipment with oxygen-deficient atmosphere.If a person enters an atmosphere of nitrogen, he or she can lose consciousnesswithout any warning symptoms in as little as 20 seconds. Death can follow in3-4 minutes. A person falls as if struck by a blow on the head. All personnelshould know that one deep breath of 100 percent nitrogen will be fatal.Breathing is stimulated and controlled (cerebellum) by carbon dioxide present inthe lungs. 100 percent nitrogen will displace carbon dioxide completely. In theabsence of a carbon dioxide signal to the brain, breathing stops. Personnelshould not work in or enter atmospheres with oxygen concentration below 19.5percent or above 23.5 percent, unless equipped with a self-contained breathingapparatus or breathing air mask. This is also true of rescue personnel who canbe overcome by the same oxygen-deficient atmosphere as the initial victim.

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Equipment SpecificationsExamples below may be specific toNorth America. Check with yourcountry standards or involve a localengineering company.

Lines, valves, pumps, and fittings canbe of ordinary carbon steel or ductileiron.

Note: Do not use cast iron due to itsbrittleness. Also avoid aluminum,magnesium, copper, tin, zinc, lead,and their alloys due to their potentialreaction with epichlorohydrin.

Spiral-wound gaskets withpolytetrafluoroethylene (PTFE) filler,flexible graphite filler, or filled PTFEgasket (e.g. Gylon 3510 or Durlon9000) have been used satisfactorily.Centrifugal pumps equipped withdual mechanical seals or magnetically-driven (seal-less) generally providegood protection for workers.

When mechanically sealed pumps areused a combustible gas detector (ex-detector) is recommended. The gasdetector should be located near eachepichlorohydrin pump to detect anypump seal leaks.

The number of flanged connectionsshould be kept at a minimum tominimize fugitive emissions. Exteriorpainting is also suggested.

Threaded connections should be keptto an absolute minimum and nosteam tracing should be used onpiping.

Table 10, page 28 provides guidelinesfor tank piping and other equipmentused for epichlorohydrin storage andtransfer systems. For specificinformation about tank hardware,consult with a professionalengineering firm and, if desired,discuss engineering specificationswith Dow. Talk to your Dowrepresentative or contact yournearest Dow location.

Table 12: Equipment Specifications

Dow suggests stainless steel (316 SS) equipment be used to store and handleepichlorohydrin. Carbon steel is also a suitable construction material.

Gaskets Spiral-wound, 304 stainless steel or Monel winding, PTFE orflexible graphite filler, 0.175" thick, API-601 for ASME/ANSI B16.5flanges, carbon steel centering ring, no inner ring.

Flat ring: filled PTFE, 1/16" thick, Gylon 3510, Blueguard 3700 orDurlon 9000.

Dry Break Valves e.g Civacon for the 1 1/2" and 2" female couplers and maleadapters respectively.

Note: dry-break couplings are currenly used only in NorthAmerica.

“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-toxicpurge.

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 temperatureprotection.

All equipment should be grounded.

Note: The customer is advised to employ a qualified engineering service todesign and build its storage and handling facility. Since any assistancefurnished by Dow with reference to the safe delivery, storage, use and disposalof its products, is provided without charge, Dow assumes no obligation orliability.

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Please consult your Dow representative for analytical methods for testingthe quality of epichlorohydrin, analyzing trace amounts of epichloro-

hydrin in water, and monitoring epichlorohydrin (and diglycidyl ether) in air.

The Dow assay method for epichlorohydrin is applicable to epichlorohydrinhaving 99.0 percent or greater purity. Impurities are determined and the sumof those concentrations is subtracted from 100 percent. The complete Dowanalytical 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 thesafety precautions suggested by the reagent supplier.

• Each analyst should be acquainted with the potential hazards of thereagents, products, and solvents before commencing laboratory work.Sources of information include: MSDS/SDS, technical and productliterature, and other related data. Safety information on non-Dow productsshould be requested from the relevant supplier. Disposal of reagents,reactants, and solvents must be in compliance with applicable governmentrequirements within your country.

Other Useful MethodsThe following sources are useful methods for testing epichlorohydrin. Theyare available from the ASTM International, 1916 Race Street, Philadelphia,Pennsylvania 19103, U.S.A.

• “Water in Liquid Petroleum Products by Karl Fischer Reagent,” DesignationASTM E-203.

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

Analytical MethodsDO

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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 ListingEpichlorohydrin (CAS Number 106-89-9) is listed in the following nationalchemical inventories:

National Chemical Chemical Substance Inventory numberInventory Inventory

Australia AICS 106-89-8

Canada DSL 683

China SEPA 106-89-8

European Community EINECS / ELINCS 203439867/548/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 106-89-8Component Substance to beconsidered for transfer(April 2003)

Philippines PICCS 106-89-8

Switzerland Giftliste 1 G-1614

USA TSCA 106-89-8

Regulatory Requirements

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- 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


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International Transportation RequirementsSection 14 of the country-specific MSDS/SDS provides details about thetransportation restrictions and labeling requirements. The details providedbelow reflect the international transportation classification status for the year2006.

Road & RailProper 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

SeaProper 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

AirProper 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.

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If you would like additional information about DOWTM Epichlorohydrin, orif you have questions about any of the topics discussed in this manual,

please contact your Dow representative or call one of the following numbersfor 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

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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 (prefix990), France, Germany, Hungary, Ireland, The Netherlands, Norway,Portugal, Spain, Sweden, Switzerland, and the United Kingdom.

Emergency Response

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

Benelux: Belgium/NetherlandsTerneuzen, Netherlands +31 115 69 4982

Eastern Europe/Israel/Middle East/AfricaTerneuzen, Netherlands +31 115 69 4982

FinlandHamina, Finland +358 5 730 2400

FranceDrusenheim, France +33 388 53 3676

GermanyStade, Germany +49 4146 91 2333

Product Safety Information, Rheinmuenster, Germany +49 7227 91 2200

GreeceLavrion, Greece +30 2920 62297

Iberia: Spain/PortugalTarragona, Spain +34 977 54 3620

IndiaMumbai, India +91 22 6797 8600

ItalyLivorno/Priolo, Italy +39 335 697 9115

Scandinavia: Sweden/Norway/DenmarkNorrkoeping, Sweden +46 8 640 9011

Switzerland/AustriaProduct Safety Information, Rheinmuenster, Germany +49 7227 91 2200

TurkeyDilovasi, Turkey +90 262 754 5174

United Kingdom/EireKings Lynn, United Kingdom +44 1553 76 1251

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Asia Pacific

Customer Information Group+800 7776 7776# (toll free)

+60 3 7958 3392#except Indonesia and Vietnam

Emergency Response

Australia1800 033 882 (toll free)

China+86 532 8388 9090

Hong Kong+852 2431 3300

Indonesia+62 254 57 1369

JapanEmergency Response +81 120 00 1017

Product Safety Information +81 3 5460 2100

Korea+82 2 551 0601

Malaysia1800 80 1255 (toll free)

Philippines+63 43 485 0411

Singapore1800 332 3543 (toll free), +65 6332 3543

Taiwan+886 49 226 0560

Thailand+66 3 868 3210

Vietnam+84 903 99 6653

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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

BrazilGuaruja +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

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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. Theinformation 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-Dowfacilities 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’sresponsibility 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 incompliance 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 WARRANTIESARE GIVEN; ALL IMPLIED WARRANTIES OF MERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE ARE EXPRESSLY EXCLUDED. Dowdoes 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.

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

Epichlorohydrin Safety

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