# Disconnect between IBC and SDS



## YongMNLad (Apr 3, 2018)

Hello all,

I would like to get input from others on an issue that I frequently run into.  I often am tasked with completing code reviews for buildings used for storage of agricultural products.  This involves me reading through multiple Safety Data Sheets to determine the occupancy of the buildings and finding products that may create issues.

My confusion normally comes with Toxic material classification.  The IBC appears to have a black and white definition when it comes to Toxic materials.  Chapter 2 defines Toxic as; a chemical falling within any of the following:

1. Lethal threshold of orally administered to *albino rats* (paraphrased for simplification)

2. Lethal threshold of continuous contact with skin of *albino rabbits* (paraphrased for simplification)

3. A chemical that has a median lethal concentration (LC50) in air of more than 200 parts per million, but not more than 2,000 parts per million by volume of gas or vapor, or *more than 2 milligrams per liter but not more than 20 milligrams per liter of mist*, fume or dust, when administered by continuous inhalation for *1 hour* (or less if death occurs within 1 hour) to *albino rats* weighing between 200 and 300 grams each.

Seems simple enough.  Then I read Section 11 of a SDS that reads:

Example 1:
Acute
Inhalation LC50           Rat      *>1,000 mg/m^3, 8 hours*
Oral LD50                   Rat      2,840 mg/kg

Example 2:
Oral LD50 = *472 mg/kg (Rat)*   (IBC oral threshold is 50-500 mg/kg, I did not list above)
Dermal LD50 > 2*g/kg (Rat)*      (note the units and specimen do not match the IBC)
Inhalation LC50 > *2.95 mg/l*

Example 3:
Acute Toxicity (Oral LD50):                3,200 mg/kg (rat). May be harmful if swallowed
Acute Toxicity (Dermal LD50):           No LD50 data available. May be harmful in contact with skin.
Acute Toxicity Inhalation LC50:          *3.05 mg/L/4.5 hour* exposure to dust/mist of undiluted material. Harmful if inhaled.

Example 4:
Acute oral toxicity:                  For similar material(s): LD50, Rat, female, 1,849 mg/kg
Acute dermal toxicity:             For similar material(s): LD50, *Rat*, >5,000 mg/kg
Acute inhalation toxicity:         For similar material(s): LC50, *Rat, 4 Hour*, dust/mist, *1.4 mg/l*

Example 5:
Ingestion:        Oral (LD50 Rat):                     >5000 mg/kg body weight
Dermal:           Dermal (LD50 Rat):                >5000 mg/kg body weight
Inhalation:       Inhalation (LC50 *Rat*):            *>2.56 mg/l*

Of the 20 materials that I have been looking at for this building, I have flagged these 5 as being toxic by IBC definition.

To add some confusion, here is a product that I did not flag as toxic:
Oral:                LD50, rat: 695 mg/kg
Inhalation:       LC50, rat: *>5.6 mg/kg, 4 hour exposure*
Dermal:           LD50, *rat*, >5,000mg/kg (OECD Guideline 402)

Although the LC50 is not greater than 20 mg/l as the IBC requires, I assume this product is non-toxic due to the 4 hour exposure. I have found testing guidelines that somewhat explain a conversion between 1 hour and 4 hour exposure tests. Take the United Nations Part 3 Health Hazards for instance:

“Values for inhalation toxicity are based on 4 hours tests in laboratory animals. When experimental values are taken from tests using a 1 hour exposure, they can be converted to a 4 hour equivalent by dividing the 1 hour value by a factor of 2 for gases and vapours and 4 for dusts and mists.”

Thus I take the LC50 of 5.6 x 4 and get 22.4 which is now considered non-toxic by the IBC definition.  The majority of the LC50 values that I see are labeled 4 hour exposure or do not list an exposure time. Because of this (and my x4 calculation) I normally do not flag a material if the LC50 is >5.

I guess my main question is, how are we supposed to accurately classify materials when the IBC does not line up with the SDS. Common “misalignments” include:

Exposure times (1 hr, 4hrs, 4.5 hrs, 8 hrs)
Units (mg/l, mg/m^3, g/l)
Tested specimen (rats, mice, rabbits)

Base on the provided information, would you (enter Ron??) classify these 6 materials as hazardous?

Thanks in advance for your time!


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## YongMNLad (Apr 3, 2018)

I should note that I am typically using the 2012 IBC in non-California states.

Also, a follow-up question. If a material is considered Toxic and the building contains more than 125 pounds (Table 307.1(2)), the building is classified as an H-4 occupancy. 903.2.5 requires Group H occupancies to have automatic sprinkler systems...

If a material is non-combustible but killed a rat when inhaled for 1-4 hours in a test, what is the thought process that an automatic fire suppression reduces the hazard of the material? - I hope this doesn't sound like I'm trying to "fight the code", I'm simply asking so I can better understand and explain to my clients when they ask this question.


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## cda (Apr 3, 2018)

Yep agree, some chemicals are hard to easily classify.

As an ahj I would ask for a report from a third party FPE or similar.

That is my suggestion, have a FPE friend that can help you occasionally, it will help you  in the long run.

Plus let me try to remember the software you can get to sometimes help you.


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## cda (Apr 3, 2018)

The ifc does have examples ::


https://codes.iccsafe.org/public/document/IFC2018/APPENDIX-E-HAZARD-CATEGORIES


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## YongMNLad (Apr 3, 2018)

cda said:


> Plus let me try to remember the software you can get to sometimes help you.



I did purchase the ICC software when I was reviewing a building with over 200 materials. Not one of the materials were in the software....

edit: found it - HMEX: The Hazardous Material Expert Assistant CD-ROM, Version 6 $260.35 

Not only did it not contain 1 material I was looking for, laptops don't even come with a cd drive anymore...


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## ADAguy (Apr 3, 2018)

It appears we have another case of a molehill becoming a mountain.
So many rules and reg's to keep aligned and many for which expirations don't align with ICC too.


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## cda (Apr 3, 2018)

YongMNLad said:


> I should note that I am typically using the 2012 IBC in non-California states.
> 
> Also, a follow-up question. If a material is considered Toxic and the building contains more than 125 pounds (Table 307.1(2)), the building is classified as an H-4 occupancy. 903.2.5 requires Group H occupancies to have automatic sprinkler systems...
> 
> If a material is non-combustible but killed a rat when inhaled for 1-4 hours in a test, what is the thought process that an automatic fire suppression reduces the hazard of the material? - I hope this doesn't sound like I'm trying to "fight the code", I'm simply asking so I can better understand and explain to my clients when they ask this question.




Nope all H’s are automatic sprinkler requirement. Fire suppression only, normally, they do other things in some situations


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## cda (Apr 3, 2018)

YongMNLad said:


> I did purchase the ICC software when I was reviewing a building with over 200 materials. Not one of the materials were in the software....
> 
> edit: found it - HMEX: The Hazardous Material Expert Assistant CD-ROM, Version 6 $260.35
> 
> Not only did it not contain 1 material I was looking for, laptops don't even come with a cd drive anymore...




Ok sorry icc is behind the times


FPE highly suggested, saves some brain cells, and ahj’s love them.


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## cda (Apr 3, 2018)

YongMNLad said:


> I did purchase the ICC software when I was reviewing a building with over 200 materials. Not one of the materials were in the software....
> 
> edit: found it - HMEX: The Hazardous Material Expert Assistant CD-ROM, Version 6 $260.35
> 
> Not only did it not contain 1 material I was looking for, laptops don't even come with a cd drive anymore...




So were any of your stuff in one of these lists::


https://codes.iccsafe.org/public/document/IFC2018/APPENDIX-E-HAZARD-CATEGORIES


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## YongMNLad (Apr 3, 2018)

cda said:


> So were any of your stuff in one of these lists::
> 
> 
> https://codes.iccsafe.org/public/document/IFC2018/APPENDIX-E-HAZARD-CATEGORIES



The materials I look at are usually compounds made up of 2-6 chemicals. I checked E102.1 and E102.2 from the link and did not find any matching chemicals.


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## cda (Apr 3, 2018)

YongMNLad said:


> The materials I look at are usually compounds made up of 2-6 chemicals. I checked E102.1 and E102.2 from the link and did not find any matching chemicals.




Ok

I am not good with toxic either. My rat brain just does not compute.

And add compounds to it.


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## cda (Apr 3, 2018)

YongMNLad said:


> Hello all,
> 
> I would like to get input from others on an issue that I frequently run into.  I often am tasked with completing code reviews for buildings used for storage of agricultural products.  This involves me reading through multiple Safety Data Sheets to determine the occupancy of the buildings and finding products that may create issues.
> 
> ...





If you post your question here, there is a great haz mat person on the site It may take a little to get back to you:::




http://www.eng-tips.com/threadminder.cfm?pid=184&page=1


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## north star (Apr 3, 2018)

*@ ~ @ ~ @*

YongMNLad,

*Recommendation # 1:* Call ICC and request either a Verbal Technical
Opinion, or Written Technical Opinion on your questions.......Costs
may be involved.

*Recommendation # 2:* Call ICC and request the e-mail address
to one of their instructors, ...a Mr. Terrell Stripling......He is one
of their regular instructors and an FPE.

*Recommendation # 3:* Send a Private Message ( PM ) to one
of the Forum members, ...****hazmatpoobah***......He visits here
infrequently, so it may take some time.

*Recommendation # 4:* Visit another Forum called Eng-Tips.com.
They have a variety of engineers and other professionals that
frequent that Forum......This Forum is somewhat challenging
to navigate until you have done it a few times, but it is FREE.
Just create your own Username & Password.

*Recommendation # 5:* Continue searching the internet for
information........The answers that you are seeking ARE out
there !

*Request # 1:*  Whenever you have found the definitive
answers, please come back on here and tell us !

*Request # 2:*  Would you also consider becoming a Paid
Subscription member on this Forum [ i.e. -  a Sawhorse ] ?
A 2 year subscription is only $60.00......Thanks for your
consideration.  


*@ ~ @ ~ @*


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## YongMNLad (Apr 3, 2018)

CDA and north star,
Thank-you for the recommendations, I will look into all of them.



north star said:


> *Request # 1:*  Whenever you have found the definitive
> answers, please come back on here and tell us !
> 
> *Request # 2:*  Would you also consider becoming a Paid
> ...



I will most definitely include an update when I have answers.

I have been a sawhorse for a couple years now, not sure why it says member on my profile. In fact, I emailed Jar about it a couple of weeks ago... Well worth the money!!


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## cda (Apr 3, 2018)

YongMNLad said:


> CDA and north star,
> Thank-you for the recommendations, I will look into all of them.
> 
> 
> ...



If you click on the person picture top right/ your profile 

Go to account upgrades

And go to the bottom it will tell you if you are an up to date paid sawhorse and when it expires


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## cda (Apr 3, 2018)

Side note::


http://specsandcodes.typepad.com/the_code_corner/control-areas/


Not sure if RGLA can help you classify



If there is a supplier of the compounded materials,  they may know, because the question may have come up before.


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## cda (Apr 3, 2018)

Will look at the ifc commentary to see if it is any help.

Have you checked that?


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## cda (Apr 3, 2018)

TOXIC. A chemical falling within any of the following categories:


1.A chemical that has a median lethal dose (LD50) of more than 50 milligrams per kilogram, but not more than 500 milligrams per kilogram of body weight when administered orally to albino rats weighing between 200 and 300 grams each.


2.A chemical that has a median lethal dose (LD50) of more than 200 milligrams per kilogram but not more than 1,000 milligrams per kilogram of body weight when administered by continuous contact for 24 hours (or less if death occurs within 24 hours) with the bare skin of albino rabbits weighing between 2 and 3 kilograms each.


3.A chemical that has a median lethal concentration (LC50) in air of more than 200 parts per million but not more than 2,000 parts per million by volume of gas or vapor, or more than 2 milligrams per liter but not more than 20 milligrams per liter of mist, fume or dust, when administered by continuous inhalation for 1 hour (or less if death occurs within 1 hour) to albino rats weighing between 200 and 300 grams each.




HIGHLY TOXIC. A material which produces a lethal dose or lethal concentration which falls within any of the following categories:

1.A chemical that has a median lethal dose (LD50) of 50 milligrams or less per kilogram of body weight when administered orally to albino rats weighing between 200 and 300 grams each.


2.A chemical that has a median lethal dose (LD50) of 200 milligrams or less per kilogram of body weight when administered by continuous contact for 24 hours (or less if death occurs within 24 hours) with the bare skin of albino rabbits weighing between 2 and 3 kilograms each.


3.A chemical that has a median lethal concentration (LC50) in air of 200 parts per million by volume or less of gas or vapor, or 2 milligrams per liter or less of mist, fume or dust, when administered by continuous inhalation for one hour (or less if death occurs within 1 hour) to albino rats weighing between 200 and 300 grams each.

Mixtures of these materials with ordinary materials, such as water, might not warrant classification as highly toxic. While this system is basically simple in application, any hazard evaluation that is required for the precise categorization of this type of material shall be performed by experienced, technically competent persons.


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## cda (Apr 3, 2018)

Example 1:
Acute
Inhalation LC50 Rat *>1,000 mg/m^3, 8 hours*
Oral LD50 Rat 2,840 mg/kg


Does not look like it meets toxic?

Greater than three hours?


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## cda (Apr 3, 2018)

A good maybe toxic

Hits the 50-500


Example 2:
Oral LD50 = *472 mg/kg (Rat)* (IBC oral threshold is 50-500 mg/kg, I did not list above)
Dermal LD50 > 2*g/kg (Rat)* (note the units and specimen do not match the IBC)
Inhalation LC50 > *2.95 mg/l*


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## cda (Apr 4, 2018)

YongMNLad said:


> CDA and north star,
> Thank-you for the recommendations, I will look into all of them.
> 
> 
> ...




Commentary does not help much, still have to look at the toxic chapter


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## cda (Apr 4, 2018)

YongMNLad said:


> Hello all,
> 
> I would like to get input from others on an issue that I frequently run into.  I often am tasked with completing code reviews for buildings used for storage of agricultural products.  This involves me reading through multiple Safety Data Sheets to determine the occupancy of the buildings and finding products that may create issues.
> 
> ...



And I guess you use 5003.11 IFC 2015, when you can


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## cda (Apr 4, 2018)

Well chapter 60 of the IFC commentary was no help.


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## cda (Apr 4, 2018)

Have not seen this book, so not sure if it would help,

Maybe if some else has read it??

https://www.barnesandnoble.com/w/pa...cology-toxicology-george-d-clayton/1122199362


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## YongMNLad (Apr 4, 2018)

cda said:


> Example 1:
> Acute
> Inhalation LC50 Rat *>1,000 mg/m^3, 8 hours*
> Oral LD50 Rat 2,840 mg/kg
> ...



I made a little progress last night. I found my HMEX CD and a computer that still has a CD-Rom drive. The Example 1 material is not a compound and was in the HMEX database. HMEX indicated that it is not toxic. 

Example 2 is also not a compound and was in the HMEX software. This product is toxic according to HMEX.

Unfortunately, the other 4 materials are either multi-chemical compounds or are not in the software.


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## YongMNLad (Apr 4, 2018)

cda said:


> If you click on the person picture top right/ your profile
> 
> Go to account upgrades
> 
> And go to the bottom it will tell you if you are an up to date paid sawhorse and when it expires





I'm able to attach and see images, according  to my Account Upgrades I'm paid up... seems the only thing off is the title under my name


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## cda (Apr 4, 2018)

YongMNLad said:


> I made a little progress last night. I found my HMEX CD and a computer that still has a CD-Rom drive. The Example 1 material is not a compound and was in the HMEX database. HMEX indicated that it is not toxic.
> 
> Example 2 is also not a compound and was in the HMEX software. This product is toxic according to HMEX.
> 
> Unfortunately, the other 4 materials are either multi-chemical compounds or are not in the software.




Well I hit 50 %!!!

Can you look on hmex at the individual ingredients and see if they are toxic by themselves, might give you an indicator


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## cda (Apr 4, 2018)

YongMNLad said:


> View attachment 2814
> 
> I'm able to attach and see images, according  to my Account Upgrades I'm paid up... seems the only thing off is the title under my name




We can give you many titles!!


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## YongMNLad (Apr 4, 2018)

cda said:


> Side note::
> 
> http://specsandcodes.typepad.com/the_code_corner/control-areas/
> 
> ...



I told myself that I wouldn't spend time on this today as I'm preparing for a meeting on another project, but here I am...

I have read through all of RGLA's keynotes, code corners over the years. Today, I revisited this article that you linked. I think this is going to get me on the right track. 
	

		
			
		

		
	




RGLA references Section 14 and the DOT classifications. I'm thinking that this will take the conversions out of the equation if the DOT has already done this. If this is the correct direction to go, now I just need to know how to correlate DOT classifications to the IBC.


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## north star (Apr 4, 2018)

*% * %*

YongMNLad,

If you have not already obtained the e-mail address
to Mr. Stripling and still want it, then send me a PM
and I will provide it to you.

*% * %*


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## fatboy (Apr 4, 2018)

My only contribution to this thread.............YongMNLad, not sure why you did not have a title change, maybe Jeff can figure it out, you are definitely paid up as a sawhorse, many thanks, sorry it was not shown. It is now. *https://www.thebuildingcodeforum.com/forum/members/yongmnlad.4418/*


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## YongMNLad (Apr 5, 2018)

fatboy said:


> My only contribution to this thread.............YongMNLad, not sure why you did not have a title change, maybe Jeff can figure it out, you are definitely paid up as a sawhorse, many thanks, sorry it was not shown. It is now.



Thanks fatboy!
<--- I'm part of the club again.
Random question, how was the term "Sawhorse" selected?  What's the meaning behind it?


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## YongMNLad (Apr 5, 2018)

cda said:


> Side note::
> 
> http://specsandcodes.typepad.com/the_code_corner/control-areas/
> 
> ...



Short update. Reading the small-print caption in RLGA's High-Hazard Occupancies Code Corner, it seems you are able to translate the USDOT numerical classification to the IBC classification.

If anyone has a resource for this translation, it would be greatly appreciated.


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## cda (Apr 5, 2018)

YongMNLad said:


> Short update. Reading the small-print caption in RLGA's High-Hazard Occupancies Code Corner, it seems you are able to translate the USDOT numerical classification to the IBC classification.
> 
> If anyone has a resource for this translation, it would be greatly appreciated.




Not sure if E101.1 is part of your answer

https://www2.iccsafe.org/states/oregon/07_fire/07_PDFs/Appendix E_Hazard Categories.pdf


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## cda (Apr 5, 2018)

Check slide 147

Purple book


http://www.scfiremarshal.llronline.com/Certification/FORMS/3rd Quarter Full Color.pdf


Have not heard of it


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## cda (Apr 5, 2018)

https://www.unece.org/fileadmin/DAM/trans/danger/publi/ghs/ghs_rev06/English/ST-SG-AC10-30-Rev6e.pdf


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## hazmatpoobah (Apr 5, 2018)

The classification of hazardous materials to determine if they are classified as a Toxic or Highly Toxic is dependent on a review of the toxicity data. My source that I use is Sax’s Handbook of Dangerous Industrial Chemicals. Currently I have the 11th edition and it costs about $800. One can use the internet to look for this information but Sax’s produces the best work and references peer-reviewed toxicity data.

If you don’t have an understanding of the recognized pathways for toxins, factors that influence toxicity, or how LC50 or LD50 is derived (and can be misused), one should seek technical assistance. Commonly, everyone says call a Fire Protection Engineer. However, if you’re being asked to evaluate the hazardous material(s) I’ve found that a Certified Industrial Hygienist (CIH) has the required knowledge to make a determination in these matters.

The codes are NOT misaligned with the safety data sheets (SDS). The toxicity values in the IFC and IBC are based on toxicity exposure limits based on OSHA regulations for poisonous materials. A common misunderstanding is how the measurements equate to exposure of the human body to a toxin. The IFC regulates toxic and highly toxic materials based on the hazardous material being inhaled, absorbed through the skin, or ingested. The measurements are expressed using the following values:

-INHALATION: Parts per million (PPM) or milligrams/cubic meter (mg/M^3). Either PPM or mg/M^3 are applied when evaluating the volume of a substance per unit volume of air of a toxin administered to a test animal that meets the species and weight requirements. Note that PPM is mathematically 1 micro liter of gas per 1 liter volume of air so mathematically they are equivalent and can be converted from one to another. However, this is dependent on the molecular weight of the gas or mist. These values are used to determine LC50.

- ABSORBTION: milligrams/square centimeter (mg/M^2). Area is the driving factor because this measurement can be used to determine the amount of a toxin is required over the area of the test animal the toxin was administered to cause 50% of the test animals to die (LD50).

- INGESTION: milligram/kilogram (mg/Kg). The mass of the toxin and the weight of the test animal are measured and used as part of the reproducible experiments to determine the mass of toxin that causes 50% of the test animals to die (LD50).

One cannot establish a limit for a hazardous material without establishing the desired or undesired response. In the IFC the response is expressed as LC50 or LD50 and it is a time-exposure dependent value. That’s why the IFC sets the measurement based on a 1-hour exposure. As you found, LC50 values can be normalized to one-hour based if the measured results were for a different time period. We use to have these values in the 2000, 2003, and 2006 editions of the IFC Appendix because the code was changed to reference a Compressed Gas Standard for the classification of gases. I’ve included them below:

*Normalization Factor*

Time (hrs)  Multiplier

0.5            0.7
1               1
1.5            1.2
2               1.4
3               1.7
4                2
5                2.2
6                2.4
7                2.6
8                2.8


Please note you cannot normalize an LD50 value for absorption because the measurement is based on the area of exposure. The same holds true for ingestion because the measurement is based on the weight of the doses and the test animals.

I’m not sure how else I can help you other than by classifying the hazardous materials. That would be awesome for you but I’m busy working for a little jurisdiction in Texas. If you have more questions ask, but I don’t come around here much because I’ve got other things more fun in my life like my job, going to the gym, cooking, and drinking bourbon.


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## cda (Apr 5, 2018)

Yeaaaa.  Haz is back


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## my250r11 (Apr 6, 2018)

hazmatpoobah said:


> If you have more questions ask, but I don’t come around here much because I’ve got other things more fun in my life like my job, going to the gym, cooking, and drinking bourbon.


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## north star (Apr 6, 2018)

*& * & * &*


> " *YongMNLad asked:  Random question, how was the term "Sawhorse" selected? What's the meaning behind it. " *


*The term "Sawhorse" was created by the Forum owner [ as I remember it ],*
in an effort to provide some sort of creative title \ benefit to those who
desire to participate on this Forum, by having a Paid Subscription to it.
The term Sawhorse is a play-on-words that relates to the type of Forum
this is  [  i.e. - construction stuff  ], and ones participation by membership
of "supporting" this valuable resource.  

*& * & * &*


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## fatboy (Apr 6, 2018)

I thought maybe ICE had suggested the term, when jar asked for suggestions.

But.......I can't say for sure.


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## north star (Apr 6, 2018)

*$ ~ $ ~ $*

***fatboy***, I'm not sure about who actually came up with the
suggestion......Maybe ***ICE*** DID suggest it first......If so,
my mistake, and my humble apologies to ***ICE***........We
can say that ***ICE*** and Jeff contributed to the suggestion
of identifying the Paid Subscription members as Sawhorses.

Whoo Hoo ***ICE*** and Jeff !

Either way, I still like the suggested title of becoming a
Sawhorse.  

*$ ~ $ ~ $*


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## Francis Vineyard (Apr 7, 2018)

I believe it was Brugers that suggested sawhorse, who had been participating on Stack Exchange


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## fatboy (Apr 7, 2018)

I believe you are correct Francis...........


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## north star (Apr 8, 2018)

*& * & * &*

Alright, let's try this again !.......A previous Forum
member named ***brudgers*** came up with the suggestion
of identifying those who have a Paid Subscription to this
Forum, ...as a Sawhorse !.......Thanks ***Francis Vineyard*** !

I wonder if ***YongMNLad*** is still reading this Topic.

*& * & * &*


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## Francis Vineyard (Apr 9, 2018)

Thought provoking: https://www.thebuildingcodeforum.com/forum/threads/change-forum-supporter-to-sawhorse.5764/


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## cda (Apr 9, 2018)

Francis Vineyard said:


> Thought provoking: https://www.thebuildingcodeforum.com/forum/threads/change-forum-supporter-to-sawhorse.5764/




A lot of people from the past!!!

Hope they are all doing great!

Wish they would just check in once in awhile and say hay!!!!


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