# Tyco Fire Protection Products — Hazardous Materials Safety Interpretation

**Citation:** 17-0066  
**Type / status:** guidance / guidance  
**Agency:** Pipeline and Hazardous Materials Safety Administration  
**Effective:** Not stated  
**Published:** 2017-12-28

17-0066 response to Tyco Fire Protection Products concerning 173.120, 173.22.

## Document text

<<<PAGE 1>>>

U.S. Department
of Transportation
Pipeline and Hazardous
Materials Safety
Administration
NOV 162017
1200 New Jersey Avenue, SE
Washington, DC 20590
Kym Seth
Manager, Hazard Communications & Product Stewardship
Tyco Fire Protection Products
2700 Industrial Parkway South
Marinette, WI 54143
Reference No. 17-0066
Dear Ms. Seth:
This letter is in response to your June 13, 2017, email requesting clarification of the Hazardous
Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to classification. You describe
your material as a highly-concentrated, water-based surfactant solution with a flash point of
23 cc and a boiling point of greater than 100 cc, which is not capable of sustaining combustion.
Specifically, you ask if the material is considered a Class 3 flammable liquid under the HMR.
As specified in § 173 .22 of the HMR, it is the shipper' s responsibility to properly class and
package a hazardous material. This Office does not normally perform this function. The HMR
define a flammable liquid as having a flash point of not more than 60 cc. Per§ 173.120(a)(3),
for your material to be exempted from classification as a Class 3 material, it must have a flash
point of greater than 35 cc. Since your material does not have a flash point of greater than
35 cc, it is the opinion ofthis Office that the material in question is a Class 3 flammable liquid.
If experience or other data indicate that the hazard of flammable liquid or combustible liquid
material is greater or less than indicated by the criteria specified in§ 173.120(a) or (b), the
Associate Administrator of Hazardous Materials Safety may revise the classification or make the
material subject or not subject to the requirements of the HMR (see § 173 .120( d) ).
I hope this information is helpful. Please contact us if we can be of further assistance.
Sincerely,
T. Glenn Foster
Chief, Regulatory Review and Reinvention
Standards and Rulemaking Division

<<<PAGE 2>>>

Dodd, Alice (PHMSA)
From:
Sent:
To:
Subject:
Attachments:
INFOCNTR (PHMSA)
Wednesday, June 14, 2017 1:41 PM
Hazmat Interps
FW: Interpretation Letter Request
4221
_001.pdf
Hi Shante/Alice,
Please submit this as a letter on interpretation. Please let me know if you have any questions.
Thanks,
Jordan
From: Seth, Kimberley [mailto:kseth@tycoint.com]
Sent: Tuesday, June 13, 2017 12:45 PM
To: PHMSA HM lnfoCenter <PHMSAHMlnfoCenter@dot.gov>
Subject: Interpretation Letter Request
We recently submitted a sample to determine flammability for purposes of transport. Both the UN and 49CFR standards
allow exceptions to the classification of flammable liquids (Class 3). According to the above standards, "liquids with a
flashpoint greater than 35°C that do not sustain combustion" are exceptions to the Class 3 definition of a flammable
liquid.
Our product is a highly concentrated (40% solids) water-based surfactant solution with the following characteristics:
• Flash point: 23°C (mainly due to the presence of t-butanol)
• Boiling point: >100°C
• Does not support sustained combustibility according to the test protocols of the UN and 49CFR standards. (I
have attached the test report from Stresau Laboratory)
According to the test results, we believe our product is not a flammable liquid despite its flash point lower than the 35°C
mentioned in the standards.
I would appreciate it if you could give us an official interpretation on whether our product is a Class 3 flammable liquid
or not?
Kind regards,
Kym Seth
Kym Seth I Manager, Hazard Communication & Product Stewardship I Tyco Fire Protection Products
2700 Industrial Parkway South, Marinette, WI 54143 USA
Tel: 1-715-735-7411 ext. 73522 I Mobile: 1-715-584-7049 I Fax: 1-715-732-3632
kseth@tycoint.com
http ://www.tyco.com
CONFIDENTIALITY NOTICE: This e-mail message, including any attachments, is for the sole use of the intended recipient(s) and may contain confidential and
privileged information or otherwise protected by law. Any unauthorized review, use, disclosure or distribution is prohibited . If you are not the intended recipient,
please contact the sender by reply e-mail and destroy all copies of the original message. Any applicable rights to privilege have not been waived.
Tyco's vision is Zero Harm to people and the environment. Please consider the environment before printing this message.
1

<<<PAGE 3>>>

This e-mail contains privileged and confidential information intended for the use of the addressees named above. If you are not the intended recipient of this e-
mail, you are hereby notified that you must not disseminate, copy or take any action in respect of any information contained in it. If you have received this e-mail in
error, please notify the sender immediately by e-mail and immediately destroy this e-mail and its attachments.
2

<<<PAGE 4>>>

STRESAU
L AB O l< AT C) nY. l hJ C
"Excellence in Energetics"
N8265 Medley Road , Spooner, WJ 5480 I
Phone: 715-635-2777
Fax : 715-635-7979
www.stresau.com
June 13, 2017
Ms. Martina Bowen
Tyco Fire Protection Products
One Stanton Street
Marinette, WI 54143
Dear Ms. Bowen:
Enclosed please find Laboratory Report# 17064 for Sustained Combustibility Analysis of your sample.
Full details are in the enclosed report.
An invoice to cover the cost of the laboratory examinations will be sent to your accounting department
under separate cover.
We appreciate your business and look forward to working with you in the future. If we may be of further
assistance, or if you have any questions, please call me at (715) 635-2777.
Sincerely,
,.ZZ,...._ ~. €~~""'-
Thomas E. Basham
Hazardous Materials Manager
tb (17064)
Over Forty Years of Development• Evaluation • Production of Energetic Devices
Classification• Packaging • Testing of Hazardous Materials
ISO 9001 :2008 Certified _, Wisconsin Green Tier participant
-

<<<PAGE 5>>>

S RESAU
I A D C > R A T C> I ~ Y . I N C •
·"Excellence in Energetics"
N8265 Medley Road, Spooner, WI 5480 I
Phone: 715-635-2777
Fax: 715-635-7979
www.stresau.com
LABORATORY REPORT # 17064
"SUSTAINED COMBUSTIBILTY ANALYSIS"
June 13, 2017
for
Tyco Fire Protection Products
One Stanton Street
Marinette, WI 54143
USA
Attn: Ms. Martina Bowen
Prepared by: 2?v-. L. {S •
. ..L
Thomas E. Basham
Reviewed by Ha&::~
Richard Hoff
Compliance Specialist
Over Forty Years of Development• Evaluation• Production of Energetic Devices
Classification • Packaging • esting of Hazardous Materials
ISO 9001 :2008 Certified 1 Wisconsin Green Tier participant

<<<PAGE 6>>>

STRESAU LABORATORY, INC.
June 13, 2017
LABORATORY REPORT# 17064
Page 1 of 7
Prepared for: Tyco Fire Protection Products
One Stanton Street
Marinette, WI 54143
Subject: "SUSTAINED COMBUSTIBILITY ANALYSIS"
1.0 OBJECT
One sample, identified below, was subjected to Sustained Combustibility Analysis in accordance
with the United States Department of Transportation's Code of Federal Regulations Tttle 49, Pt
173, App. Hand the United Nation's Transport of Dangerous Goods-Manual of Tests and Criteria,
Sixth revised edition (2015) (Test L.2) as requested by Martina Bowen of Tyco Fire Protection
Products. Credit Card Payment.
2.0 IDENTIFICATION AND PHYSICAL APPEARANCE
FS-221 Product Identifier 780095
Lot# 5202111
17064
Yellow liquid

<<<PAGE 7>>>

STRESAU LABORATORY, INC.
June 13, 2017
LABO RA TORY REPORT # 17064
Page 2 of 7
3.0 TEST CONDUCTED
3.1 SUSTAINED COMBUSTIBILITY TESTING
3.1 .1 SCOPE:
This test
_
is performed to determine if the tested material will sustain combustion with application
and subsequent removal of a flame at temperatures specified by the U.S. D.O.T. and the United
Nations criteria.
3.1.2 PROCEDURE:
I~; ( ,[ h. f'dll l f:i A11fH~1Hl1x fl
If I 1 • t J ~. ii , I
The sample is loaded into a Setaflash Open Cup Flashpoint Tester, Model# 01 SF Tester in 2 ml
increments and heated to ()CJ O · Cl . at standard pressure. The actual temperature, that the
material is tested at, is mathematically determined to correspond with the temperature that the
sample would be heated to at standard pressure.
A flame is then placed adjacent to the sample in a position specified by the UN as the "Off' position
for a 60 second stabilization period.
If no sustained combustion occurs in accordance with the test criteria, the flame is placed above
the sample in a position specified by the UN as the 'Test" position for an additional 15 seconds.
This process is repeated a total of three times or until sustained combustion is achieved.
If no sustained combustion is observed with a 60 second stabilization period at hO u · < ;/ , ' '
the process is repeated using a 30 second stabilization period instead of the 60 second
stabilization period.
If still no sustained combustion occurs in accordance with the test criteria with either of the
stabilization periods 60 seconds and 30 seconds, the entire procedure is repeated again with the
sample heated to 75 °C. Again, a mathematical adjustment to the test temperature is made to
reflect the actual barometric pressure.

<<<PAGE 8>>>

'
STRESAU LABORATORY, INC.
June 13, 2017
LABORATORY REPORT# 17064
Page 3 of 7
If no sustained combustion is found at test temperatures of hU (J l or f!J ( :, in the case of a
material which has a flash point above 60 °C (140 °F) and below 93 °C (200 °F), if sustained
combustion is not found at a test temperature of 5 °C (9 °F) above its flash point, repeat the
complete procedure with new portions, but at a test temperature of 20 °C (36 °F) above its flash
point.
3.1 .3 CRITERIA:
The material must be assessed either as not sustaining combustion or as sustaining
combustion. Sustained combustion must be reported at either of the heating times if one of
the following occurs with either of the test portions:
a) When the test flame is in the "Off' position, the test portion ignites and sustains
combustion.
b) The test portion ignites while the test flame is in the "Test" position for 15 seconds, and
sustains combustion for more than 15 seconds after the test flame has been returned to
the "Off' position.
3.1.4 RESULTS
3.14.1 49 C.F.R PART 173 APPENDIX H
Sample No. 17064
Date: 06/08/2017
Barometric Pressure: 733.6 mm/Hg
Temperature Correction:+ 0.9 °C
-·
Combustion Combustion
2
3

<<<PAGE 9>>>

STRESAU LABORATORY, INC.
June 13, 2017
LABORATORY REPORT # 17064
Page 4 of 7
Combustion
Combustion
2
3
3.1.4.2 49 C.F.R PART 173 APPEND IX H D ISCUSSION :
The sample did not ignite and sustain combustion in the "Off' or "Test" position for greater than
15 seconds, at test temperatures of 60 °C.
3.1 .5 U NITED NATIONS
The test was also performed at 60.5 °C in accordance with the United Nations Transport of
Dangerous Goods Manual of Tests and Criteria, Sixth revised edition (2015) to provide additional
information concerning international shipments of the material.
3. 1.5. 1 R ES UL TS
Sample No. 17064
Date: 06/08/2017
Barometric Pressure: 733.6 mm/Hg
Temperature Correction: + 0.9 °C
1
2
3
Combustion Combustion
No Ignition or Sustained
Combustion
No Ignition or Sustained
Combustion
1
2
3

<<<PAGE 10>>>

STRESAU LABORATORY, INC.
June 13, 2017
LABORATORY REPORT# 17064
Page 5 of 7
The sample did not ignite and sustain combustion in the "Off' or "Test" position for greater than
15 seconds, at test temperatures of 60.5 °C.
3.1 .6 49C.F.RPART173APPENDIXH/ I Ill 111\)/ I HI 1·
The test was also performed at 75.0 °C in accordance with the Code of Federal Regulations Title
49, Pt. 173, App. Hand the United Nations Transport of Dangerous Goods Manual of Tests and
Criteria, sixth revised edition (2015) to provide additional information concerning international
shipments of the material.
3.1.6.1 RESULTS
Sample No. 17064
Date: 06/08/2017
Barometric Pressure: 733.6 mm/Hg
Temperature Correction: + 0.9 °c
No Ignition or Sustained
Combustion Combustion
1
2
3
No Ignition or Sustained
Combustion
No Ignition or Sustained
Combustion
1
2
3
3.1.6.2 49C.F.RPART 173 APPENDIX H/lJ1 I I I hl!11 <Jfl I i l 'll1,11 11\1'
The sample did not ignite and sustain combustion in the "Off' or 'Test" position for greater than
15 seconds, at test temperatures of 75.0 °C.

<<<PAGE 11>>>

STRESAU LABORATORY, INC.
June 13, 201 7
LABORATORY REPORT # 17064
Page 6 of 7
4.0 CONCLUSIONS
Based on the test results, the following conclusions were made:
49 C.F.R PART 173 APPENDIX H
1) The material represented by sample # 17064 did not appear to sustain combustion at test
temperatures of 60.9 °C or 75.9 °C, which were raised appropriately in order to compensate
for the lower than standard barometric pressure as defined by the listed test specifications.
Since the Flashpoint was either unknown or not performed by Stresau Laboratory, Inc., the
test was not performed at 5 °C and 20 °C above its flashpoint as per the specification.
UN ITED NATIONS
2) The material represented by sample # 17064 did not appear to sustain combustion at a test
temperature of 61.4 °C, which was raised appropriately in order to compensate for the lower
than standard barometric pressure as defined by the listed test specifications.
The conclusion represents our interpretations of the test data, as defined by the above listed test
specifications. The conclusions contained in this report are for the customer's information
purpose only.
5.0 DATASTORAGE
The field data for this test is recorded in Data Book 2017-1, and will be filed with Stresau
Laboratory's Document Control. No video or photographic documentation was made.
6.0 TEST SERVICES
For the benefit of our customers, Stresau Laboratory, Inc., will on occasion, use outside
testing services to either expedite or qualify our own testing capabilities.

<<<PAGE 12>>>

STRESAU LABORATORY, INC.
June 13, 2017
LABO RA TORY REPORT # 17064
Page 7 of 7
References
Code of Federal Regulations (2015). Title 49, Transportation, Part 173; "Appendix H", National Archives
and Records Service, Office of the Federal Register Washington, D.C.
United Nations. (2015). Recommendations on the Transport of Dangerous Goods Manual of Tests and
Criteria (6th ed.). New York and Geneva: United Nations. pp 363-366.

<<<PAGE 13>>>

STRESAU
L ABOnAIOl<Y. l h J C
"Excellence in Energetics"
N8265 Medley Road, Spooner, WI 5480 I
Phone: 71 5-635-2777
rax: 7 15-635-7979
www.stresau.com
Report # 17064 Appendix A
EQUIPMENT QUALITY TRACEABILITY FORM
Customer: Tyco Fire Protection Products
Job Code: 4000
Stresau Report #: HMT 17064
Procedure #: TP 267
Date: June 13, 2017
Report by: Thomas E. Basham
Item
Mfg.
Tester
Stopwatch
Microprocessor Thermometer
Calipers
Barometer
ERDCO Engineering Corp.
Fisher Scientific
Omega Engineering, Inc.
Mitutoyo
Princo Instruments, Inc.
Model
01SF
06-662-50
HH21
CD-6"CSX
453
Stresau
Equip.#
N/A
1937
1136
1613
N/A
Quality
Status
2
2
2
Attach additional forms if needed
Equipment # = Traceable to Stresau Quality System
Status: 1 = Not in calibration system
2 = Calibration current as of date listed.
3 = Other. Attach MRR or other documentation as needed
FORM # 96C654
Over Forty Years of Development • Evaluation • Production of Energetic Devices
Classification• Packaging• Testing of Hazardous Materials
ISO 9001 :2008 Certified • Wisconsin Green Tier participant

<<<PAGE 14>>>

STRESAU
LABORATORY , I NC
"Excellence in Energetics"
N8265 Medley Road, Spooner, WI 54801
Phone: 715-635-2777
Fax: 715-635-7979
www.stresau.com
June 13, 2017
Ms. Martina Bowen
Tyco Fire Protection Products
One Stanton Street
Marinette, WI 54143
Dear Ms. Bowen:
Enclosed please find Laboratory Report# 17064 for Sustained Combustibility Analysis of your sample.
Full details are in the enclosed report.
An invoice to cover the cost of the laboratory examinations will be sent to your accounting department
under separate cover.
We appreciate your business and look forward to working with you in the future. If we may be of further
assistance, or if you have any questions, please call me at (715) 635-2777.
Sincerely,
- ~~.6~
Thomas E. Basham
Hazardous Materials Manager
tb (17064)
Over Forty Years of Development• Evaluation • Production of Energetic Devices
Classification • Packaging • Testing of Hazardous Materials
ISO 9001:2008 Certified.=., Wisconsin Green Tier participant
-
......
_.

<<<PAGE 15>>>

STRESAU
LABORATORY . IN C
"Excellence In Energetics"
N8265 Medley Road, Spooner, Wl 5480 I
Phone: 715-635-2777
Fax: 715-635-7979
www.stresau.com
LABORATORY REPORT# 17064
"SUSTAINED COMBUSTIBILTY ANALYSIS"
June 13, 2017
for ·
Tyco Fire Protection Products
One Stanton Street
Marinette, WI 54143
USA
Attn: Ms. Martina Bowen
Prepared by: ..:z4....... £". [)_,t.
Thomas E. Basham
Reviewed by: Ha~
Richard Hoff
Compliance Specialist
Over Forty Years of Development• Evaluation • Production of Energetic Devices
Classification• Packaging• Testing of Hazardous Materials
-
ISO 9001:2008 Certified_, Wisconsin Green Tier participant
-
......

<<<PAGE 16>>>

STRESAU LABORATORY, INC.
June 13, 2017
LABORATORY REPORT # 17064
Page 1of7
Prepared for: Tyco Fire Protection Products
One Stanton Street
Marinette, WI 54143
Subject: "SUSTAINED COMBUSTIBILITY ANALYSIS"
1.0 OBJECT
One sample, identified below, was subjected to Sustained Combustibility Analysis in accordance
with the United States Department of Transportation's Code of Federal Regulations Title 49, Pt
173, App. Hand the United Nation's Transport of Dangerous Goods-Manual of Tests and Criteria,
Sixth revised edition (2015) (Test L.2) as requested by Martina Bowen of Tyco Fire Protection
Products. Credit Card Payment.
2.0 IDENTIFICATION AND PHYSICAL APPEARANCE
~~~~~~~~~~~~~~~~~~~~~
FS-221 Product Identifier 780095
Lot# 5202111
17064

<<<PAGE 17>>>

STRESAU LABORATORY, INC.
June 13, 2017
LABORATORY REPORT # 17064
Page 2 of 7
3.0 TEST CONDUCTED
3.1 SUSTAINED COMBUSTIBILITY TESTING
3.1.1 SCOPE:
This test_is performed to determine if the tested material will sustain combustion with application
and subsequent removal of a flame at temperatures specified by the U.S. D.O.T. and the United
Nations criteria.
3.1 .2 PROCEDURE:
49 CFR Part 173 Appendix H
Uf\J Test Method L.2
The sample is loaded into a Setaflash Open Cup Flashpoint Tester, Model# 01 SF Tester in 2 ml
increments and heated to 60.0 "C/GO ~) "C. at standard pressure. The actual temperature, that the
material is tested at, is mathematically determined to correspond with the temperature that the
sample would be heated to' at standard pressure.
A flame is then placed adjacent to the sample in a position specified by the UN as the "Off' position
for a 60 second stabilization period.
If no sustained combustion occurs in accordance with the test criteria, the flame is placed above
the sample in a position specified by the UN as the "Test" position for an additional 15 seconds.
This process is repeated a total of three times or until sustained co.mbustion is achieved.
If no sustained combustion is observed with a 60 second stabilization period at 60 o "C/GO 5 ''C .
the process is repeated using a 30 second stabilization period instead of the 60 second
stabilization period.
If still no sustained combustion occurs in accordance with the test criteria with either of the
stabilization periods 60 seconds and 30 seconds, the entire procedure is repeated again with the
sample heated to 75 °C. Again, a mathematical adjustment to the test temperature is made to
reflect the actual barometric pressure.

<<<PAGE 18>>>

STRESAU LABORATORY, INC.
· June 13, 2017
LABO RA TORY REPORT # 17064
Page 3 of 7
If no sustained combustion is found at test temperatures of 60.0 °C or 75 °C, in the case of a
material which has a flash point above 60 °C (140 °F) and below 93 °C (200 °F), if sustained
combustion is not found at a test temperature of 5 °C (9 °F) above its flash point, repeat the
complete procedure with new portions, but at a test temperature of 20 °C (36 °F) above its flash
point.
3.1.3 CRITERIA:
The material must be assessed either as not sustaining combustion or as sustaining
combustion. Sustained combustion must be reported at either of the heating times if one of
the following occurs with either of the test portions:
a} When the test flame is in the "Off' position, the test portion ignites and sustains
combustion.
b) The test portion ignites while the test flame is in the "Test" position for 15 seconds, and
sustains combustion for more than 15 seconds after the test flame has been returned to
the "Off' position.
3.1.4 RESULTS
3.1.4.1 49 C.F.R PART 173 APPENDIX H
Sample No. 17064
Date: 06/08/2017
Barometric Pressure: 733.6 mm/Hg
Temperature Correction: + 0.9 •c
Combustion Combustion
2
3

<<<PAGE 19>>>

STRESAU LABORATORY, INC.
June 13, 2017
LABORATORY REPORT # 17064
Page 4 of 7
1
2
3
Combustion
l
Combustion
3.1.4.2 49 C.F.R PART 173 APPENDIX H DISCUSSION:
The sample did not ignite and sustain combustion in the "Off' or "Test" position for greater than
15 seconds, at test temperatures of 60 °C.
3.1.5 UNITED NATIONS
The test was also performed at 60.5 °C in accordance with the United Nations Transport of
Dangerous Goods Manual of Tests and Criteria, Sixth revised edition (2015) to provide additional
information concerning international shipments of the material.
3.1 .5.1 RESULTS
Sample No. 17064
Date: 06/08/2017
Barometric Pressure: 733.6 mm/Hg
Temperature Correction:+ 0.9 °C
1
2
No Ignition or Sustained
Combustion
Combustiori
l l
1
2
3
Combustion Combustion

<<<PAGE 20>>>

STRESAU LABORATORY, INC.
June 13, 2017
LABORATORY REPORT# 17064
Page 5 of 7
The sample did not ignite and sustain combustion in the "Off' or "Test" position for greater than
15 seconds, at test temperatures of 60.5 °C.
3.1.6 49 C.F .R PART 173 APPENDIX H/UJ'1!1 EJ) i 'il\rnm~; Tt : ~·, 1 L .2
The test was also performed at 75.0 °C in accordance with the Code of Federal Regulations Title
49, Pt. 173, App. Hand the United Nations Transport of Dangerous Goods Manual of Tests and
Criteria, sixth revised edition (2015) to provide additional information concerning international
shipments of the material.
3.1.6.1 RESULTS
Sample No. 17064
Date: 06/08/2017
Barometric Pressure: 733.6 mm/Hg
Temperature Correction:+ 0.9 °C
No Ignition or Sustained
Combustion
1
2
3
Combustion Combustion
3.1.6.2 49 C.F.R PART 173 APPENDIX H/U1'1: f ED l\J/1l IUW:. l f<) i L 2 DISC\ iSS J ON
The sample did not ignite and sustain combustion in the "Off" or "Test" position for greater than
15 seconds, at test temperatures of 75.0 °C.

<<<PAGE 21>>>

STRESAU LABORATORY, INC.
June 13, 2017
LABO RA TORY REPORT# 17064
Page 6of7
4.0 CONCLUSIONS
Based on the test results, the following conclusions were made:
49 C.F.R PART 173 APPENDIX H
1) The material represented by sample # 17064 did not appear to sustain combustion at test
temperatures of 60.9 °C or 75.9 °C, which were raised appropriately in order to compensate
for the lower than standard barometric pressure as defined by the listed test specifications.
Since the Flashpoint was either unknown or not performed by Stresau Laboratory, Inc., the
test was not performed at 5 °C and 20 °C above its flashpoint as per the specification.
U NITED NATIONS
2) The material represented by sample # 17064 did not appear to sustain combustion at a test
temperature of 61.4 °C, which was raised appropriately in order to compensate for the lower
than standard barometric pressure as defined by the listed test specifications.
The conclusion represents our interpretations of the test data, as defined by the above listed test
specifications. The conclusions contained in this report are for the customer's information
purpose only.
5.0 DATASTORAGE
The field data for this test is recorded in Data Book 2017-1 , and will be filed with Stresau
Laboratory's Document Control. No video or photographic documentation was made.
6.0 TEST SERVICES
For the benefit of our customers, Stresau Laboratory, Inc., will on occasion, use outside
testing services to either expedite or qualify our own testing capabilities.

<<<PAGE 22>>>

STRESAU LABORATORY, INC.
June 13, 2017
LABO RA TORY REPORT # 17064
Page 7 of 7
References
Code of Federal Regulations (2015). Title 49, Transportation, Part 173; "Appendix H", National Archives
and Records Service, Office of the Federal Register Washington, D.C.
United Nations. (2015). Recommendations on the Transport of Dangerous Goods Manual of Tests and
Criteria (6th ed.). New York and Geneva: United Nations. pp 363-366.

<<<PAGE 23>>>

S TR E SAU
LAB O RATORY . I NC
"Excellence in Energetics"
N8265 Medley Road, Spooner, WI 54801
Phone: 715-635-2777
Fax: 715-635-7979
www .stresau.com
Report # 17064 Appendix A
EQUIPMENT QUALITY TRACEABILITY FORM
Customer: Tyco Fire Protection Products
Job Code: 4000
Stresau Report#: HMT 17064
Procedure #: TP 267
Date: June 13, 2017
Report by: Thomas E. Basham
Item
Mfg.
Tester
Stopwatch
Microprocessor Thermometer
Calipers
Barometer
ERDCO Engineering Corp.
Fisher Scientific
Omega Engineering, Inc.
Mitutoyo
Princo Instruments, Inc.
Model
01SF
06-662-50
HH21
CD-6"CSX
453
Stresau
Equip.#
N/A
1937
1136
1613
N/A
Quality
Status
1
2
2
2
Attach additional forms if needed
Equipment # = Traceable to Stresau Quality System
Status: 1 = Not in calibration system
2 = Calibration current as of date listed.
3 = Other. Attach MRR or other documentation as needed
FORM # 96C654
Over Forty Years of Development• Evaluation • Production of Energetic Devices
Classification • Packaging • Testing of Hazardous Materials
-
ISO 9001 :2008 Certified _, Wisconsin Green Tier participant
'!l!llllllll!fo'
Mllil!iii;O
......

## Provenance

- Official: Yes
- Source: <https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/standards-rulemaking/hazmat/interpretations/56836/170066.pdf>
- Source ID: `phmsa`
- SHA-256: `ed1c4b93d90b0ad31151a2361576696f4fbbe1602d74c5e3c8bd176a44d7f344`
- Retrieved: 2026-08-20T00:59:31.977Z
- Exported: 2026-08-23T15:46:02.411Z
- Document slug: `phmsa-interpretation-17-0066`

### Source metadata

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