In a previous article this writer discussed the pitfalls of using only an SDS as a classification document. In this instance the petitioner had a lab test as back-up. We looked at five different suppliers of ferrosilicon SDS sheets and came up with an "assortment" of answers. The first two were basically "yes, hazardous Division 4.3 PGIII, UN 1408, flammable dusts as well, water exposure liberates Hydrogen." The first added Division 6.1 as a subsidiary hazard. The third listed the material in their section 14 as UN 1408-which if one uses a UN number to describe something are you not affirming it is hazardous? But continued to state they had independent confirmation via the UN MOTC 33.4.1.4 that it did not meet the criteria for Division 4.3, but exposure to water will liberate hydrogen. Maybe not enough to count as Division 4.3? In refencing §173.124 (c) we see Division 4.3 is a material that when wet, will be flammable or will evolve ＞ 1L/kg*hr flammable or toxic gas (§ 173.125 PG Ⅲ).
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