# Airborne Labs International, Inc. — Hazardous Materials Safety Interpretation **Citation:** 23-0096 **Type / status:** guidance / guidance **Agency:** Pipeline and Hazardous Materials Safety Administration **Effective:** Not stated **Published:** 2024-03-27 23-0096 response to Airborne Labs International, Inc. concerning 172.101, 173.115. ## Document text <<>> U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Avenue, SE Washington, DC 20590 March 27, 2024 Aniyah Volpe Shipping Administrator Coordinator Airborne Labs International, Inc. 22C World’s Fair Drive Somerset, NJ 08873 Reference No. 23-0096 Dear Ms. Volpe: This letter is in response to your October 26, 2023, email and subsequent conversation with a member of my staff requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to customer shipments of carbon dioxide (CO2) sent to your company laboratory for quality control testing of a liquid CO2 source. Specifically, your company provides sampling kits, accompanied by specific instructions, for the collection and shipment of non-liquid phase CO2 in bags and mini-cylinders. You note that the CO2 samples collected in the sample bags are essentially at atmospheric pressure, and the CO2 in the sample mini-cylinders is at 25 psig or less, where the mini-cylinders incorporate a check valve to limit the pressure of the contents. It is your understanding, based on the classification criteria for Division 2.2 gases, that CO2 transported in containers at these pressures is not regulated as a hazardous material and request confirmation. Your understanding is correct. While CO2 is listed in the § 172.101 hazardous materials table as a Division 2.2 gas, the CO2 as described in your email does not meet the definition of a Division 2.2 gas when transported in a container at pressures below 29.0 psig at 68 °F (20 °C), nor is it transported as a liquified gas or cryogenic liquid (see § 173.115(b)). Furthermore, it would remain not regulated, provided that it does not meet the criteria for a hazardous waste, hazardous substance, marine pollutant, or any other hazard class or division. I hope this information is helpful. Please contact us if we can be of further assistance. Sincerely, Dirk Der Kinderen Chief, Standards Development Branch Standards and Rulemaking Division <<>> Casey 23-0096 From: INFOCNTR (PHMSA) To: Dodd, Alice (PHMSA) Cc: Hazmat Interps Subject: FW: Request for DOT Letter of Interpretation – Non-Hazardous Sampling Kits Date: Thursday, October 26, 2023 3:57:12 PM Attachments: image001.png SOP-S-01 Rev7 ALI - No-Haz Final Product Instructions & SnowQuik LPM.pdf ALI-IATA-Definition and FedEx Letter 2023 (2).pdf IATA Guidelines Letter for Non-Haz Sampling Kit.pdf Importance: High Hi Alice, Please see the below interpretation request. Let us know if you need anything. Sincerely, Janaye From: Aniyah Volpe Sent: Thursday, October 26, 2023 2:35 PM To: PHMSA HM InfoCenter Cc: Mark Taylor ; Tracie Moran Subject: Request for DOT Letter of Interpretation – Non-Hazardous Sampling Kits Importance: High CAUTION: This email originated from outside of the Department of Transportation (DOT). Do not click on links or open attachments unless you recognize the sender and know the content is safe. Good afternoon, To whom it may concern, I hope this email finds you well. My name is Aniyah Volpe I’m writing on behalf of Airborne Labs International a Commercial Laboratory that specializes in CO2 sampling. I’m writing to request a Letter of Interpretation from the Department of Transportation (DOT) regarding an issue we’ve been encountering with our No-Haz Sampling Kits in relation to carriers and foreign customs agents. We have been experiencing a recurring problem where our kits are mistakenly classified as hazardous materials by carriers and foreign customs agents. This incorrect classification has led to delays and complications in our shipping and export processes. Furthermore, foreign customs agents have also requested MSDS for our sampling kits, by us providing the MSDS documentation would lead to the incorrect classification of our products as hazardous materials. The situation is counterproductive to our efforts to ensure the correct handling and classification of our products. <<>> In light of these issues, we kindly request the DOT’s guidance and clarification in the form of a Letter of Interpretation. Specifically, we seek your guidance on how to prevent our Non-Hazardous sampling kits from being mistakenly categorized as hazardous materials, as well as how to handle requests for MSDS in a manner that avoids the misclassification of our products. Your expertise and assistance in resolving this matter are highly valuable to us, as we are committed to upholding the safety, compliance, and efficiency of our operations. We believe that a formal interpretation from the DOT will help clarify the regulations and guidelines governing the transportation of our products and alleviate these issues. To provide you with a more comprehensive understanding of our situation, I’ve attached a copy of our (FedEx letter with IATA instructions, our personal IATA instructions letter and our Final Product CO2 manual) that we currently provide when customs does reach out regarding an issue. We are sampling gaseous Carbon Dioxide; a division 2.2 Gas and our kits are designed to only hold 25 PSIG of pressure. Thus, per IATA this isn’t hazmat as also confirmed by the attached FedEx Letter. We appreciate your prompt attention to this matter and look forward to your guidance. If you require any additional information or documentation from our end, please don’t hesitate to reach out to us. I look forward to your reply! Kind regards, ___________________________________ Aniyah Volpe Shipping Administrator Coordinator Airborne Labs International, Inc. 22C World’s Fair Drive Somerset, NJ 08873 Email: traffic@airbornelabs.com T: 732-302-1950 <<>> IATA Guidelines for Non-Hazardous Sampling Kit Reference to IATA Classification and Exceptions To Whom It May Concern, I am writing to provide important information regarding our Non-Hazardous Sampling Kit and its compliance with IATA guidelines. Please refer to the IATA guidelines (2023 Edition), specifically detailed in the IATA Classification on Page 167, Section 3.2.2.2, pertaining to gases that fall under Division 2.2, including: (a) Gases which are asphyxiant – Gases that dilute or replace the oxygen normally in the atmosphere. (b) Gases that are oxidizing – Gases that may, generally by providing oxygen, cause or contribute to the combustion of other materials more than air does. (c) Gases that do not come under other divisions. Our Non-Hazardous Sampling Kit, as indicated, does not contain gases falling under any of these classifications. Therefore, it complies with the specified IATA guidelines for Non-Flammable, Non-Toxic gases. Additionally, please refer to IATA Exceptions on Page 168, Section 3.2.2.4.1, (2023 Edition) which states that (Gases of Division 2.2 are not subject to these regulations if they are transported at a pressure less than 200 kPa at 20°C and are not liquefied or refrigerated liquefied gases.) Our Non-Hazardous Sampling Kit adheres to these criteria, confirming its exemption from certain IATA regulations. We emphasize that our Non-Hazardous Sampling Kit poses no threat during transportation, as it complies with these IATA guidelines and exceptions. It is essential to recognize that the contents of this kit are Non-Hazardous and do not present any danger to individuals, property, or the environment. Sincerely, Shipping Department 22C World’s Fair Drive Somerset, NJ 08873 USA Email: traffic@airbornelabs.com Phone: 732-302-1950 <<>> Non-Hazardous “No-Haz” Division 2.2 Gas Sample Kit Shipments by I.A.T.A. Definition Dear Customer, This letter concerns shipment of non-compressed Division 2.2 (non-flammable, non-toxic) gases including, for example: air, carbon dioxide (CO2), oxygen (O2), nitrogen (N2) argon (Ar) sulfur hexafluoride (SF6) samples in limited quantities to our laboratory for quality control testing. We have been assured by recognized experts at the International Compliance Center Ltd. and courier HAZMAT specialists that Division 2.2 gas samples that are taken according to supplied directions and shipped in our No-Haz Sampling & Shipping Kits (which include gas sampling bags, minicyls and 1L steel NVR container) can be properly labeled and shipped as a “non-hazardous commodity sample of no commercial value”. The technical reasons for this non-hazardous classification of Division 2.2 gas samples taken in our “No-HAZ” kits are as follows: 1.) Division 2.2 gases are those that have non-flammable and non-toxic properties. These gases are properly classified as dangerous materials (hazmat) only when they are compressed or liquefied. A compressed Division 2.2 gas is defined in IATA regulations as one which is “transported under pressure at or above 200 kPag (gauge) = 2.97 atm = 43.7 psia (29 psig) @ 20oC". This means that Division 2.2 gas samples should not be classified as hazmat if it is contained and shipped at a pressure less than this “compressed gas” definition value. As the pressure inside of a gas sampling bag is essentially 0 psig (14.7 psia) @ 20oC, it does not meet the conditions necessary for it to be IATA-defined as a hazardous material. Therefore non-compressed Division 2.2 gases in a sample bag is not a Div. 2.2 hazmat. The weight of Division 2.2 gas contained within a 2-3 x 2L sample bag is no more than approximately 37 g = 0.037 kg. The maximum acceptable amount of compressed gas meeting Division 2.2 HAZMAT definition requirements for passenger aircraft is 75 kg and 150 kg for cargo aircraft. 2.) The same IATA “exemption” definition descriptions outlined for a gas sampling bag also pertain to a non- compressed Division 2.2-defined gas samples stored in our minicyls. A minicyl is a small (ex. 75 – 500 cc [0.075 – 0.5L]) capacity US DOT cylinder that can be charged with no more than 25 psig of Div. 2.2 gas (fill-limited by a 25 psig check valve). Because of its design, the non-compressed, minimal amount (approx. 0.22-1.5L) of gas sample contained within a minicyl does not meet the definition of a Div 2.2 hazardous material. Therefore, non- compressed Div. 2.2 gas sample contained in a minicyl is not IATA-defined as hazardous material as per it’s “exemptions” description. 3.) Concerning our 1L NVR polished steel can, the customer takes a CO2 snow sample at their location and lets the snow evaporate within this can. This empty NVR can is then clip-lidded and shipped back within our No-Haz kit for lab examination for any trace non-volatile residue (ex. Particulates). Therefore this container is shipped as an empty can. It is the prerogative of your designed carrier to make a final decision concerning acceptance of your shipment. However, based upon the sound technical data listed above, which indicates total compliance with both the letter and spirit of IATA dangerous goods shipping regulations, ALI recommends that your kit sample be properly labeled as a “non-hazardous industrial sample of no commercial value”. Please see the attached confirmation of this letter’s contents by the Manager of Dangerous Goods – FedEx and contact us if you require assistance with your sample shipment. . Dr. Don Pachuta PRESIDENT – AIRBORNE LABS INTERNATIONAL 22C World’s Fair Drive | Somerset, NJ 08872 USA | T: (+1) 732-302-1950 | F: (+1) 732-302-3035 www.airbornelabs.com | ISO/IEC 17025:2017 Accredited Laboratory <<>> Corporate Safety 3670 Hacks Cross Road Dangerous Goods Program: Memphis, TN 38125 Module G FedEx® Express January 2023 Subject: Airborne Labs International Gas Sample Kit Shipments To Whom It May Concern: The Non-Flammable, Non-Toxic Gas Sample Kit shipments (air, carbon dioxide, oxygen, nitrogen, argon, sulfur hexafluoride) are not Dangerous Goods according to the enclosed information from Airborne Labs International when prepared according to Airborne Labs instructions. The samples are not dangerous goods when the pressure is below 200 kPa gauge pressure (29 psig, 43.5 psia) according to IATA Dangerous Goods Regulations (see section 3.2.2.4.1). These shipments do not require dangerous goods marking, labeling, or documentation, and should NOT be rejected. Please contact DG Administration at 1-901-375-6807 or 1-888-288-3786, or the DG Hotline at 1-901-375-6806 prompt 4 or 1-800-463-3339, prompt 81, prompt 4 if you have any questions concerning these shipments. Sincerely, Ig Leech II. Thomas J. Leech, I! Sr. Manager, Corporate Safety Dangerous Goods Programs Shipments by I.A.T.A. Definition" letter. Note: This letter is for use with Airborne Labs International, Inc., "Non-Hazardous "No-Haz" Division 2.2 Gas Sample Kit misinterpretations of this information. government regulations. FedEx Express accepts no liability for loss or damage resulting from changes, errors, omissions, or <<>> No-Haz LCO2 Sampling Kit™ for Final Product Testing Applications Using a SnowQuik™ Device ALI Instructional Summary© THESE INSTRUCTIONS & ALL KIT COMPONENTS MUST BE RETURNED THANK YOU! ALI PROPRIETARY / CONFIDENTIAL – FOR CUSTOMER USE ONLY – NOT TO BE FURTHER DISTRIBUTED 22C World’s Fair Drive | Somerset, NJ 08873 USA | T: (+1) 732-302-1950 | F: (+1) 732-302-3035 www.airbornelabs.com | ISO/IEC 17025:2005 Accredited Laboratory SOP-S-01 Rev 7 (08/2016) <<>> <<>> No-Haz LCO2 Sampling Kit™ Final Product Application Instructions A. SET UP A Flash Vaporizer-Pressure Regulator (VPR) MUST be employed for liquid CO2 (LCO2) sampling when using this No-Haz Kit! DANGER: DO NOT attempt to directly flow LCO2 into a sample bag or minicyl! Links to relevant instructional sampling videos can be found at the end of this packet. A Complete Final Product Test Program requires: • (2) 2L Gas Sampling Bags • (1) Minicyl (2 if an H2O test is required) • (1) 1L NVR can snow sample All to be taken from the same liquid-phase CO2 sampling port 1) Ensure the sampling area is well ventilated & personal safety gear is worn. Review all CO2 Safety Data Sheets & safety instructional tips. 2) Plug-in VPR (110 or 240 VAC models available) to an appropriate, properly grounded outlet & allow 20 min warm-up. Attach T-fitting to VPR outlet. (SEE EXHIBIT 1) 3) Install appropriate adapter fitting onto the LCO2 source valve to mate with the VPR’s 1/4” compression nut (Consult ALI for fitting adapter options if needed). 22C World’s Fair Drive | Somerset, NJ 08873 USA | T: (+1) 732-302-1950 | F: (+1) 732-302-3035 www.airbornelabs.com | ISO/IEC 17025:2005 Accredited Laboratory SOP-S-01 Rev 7 (08/2016) <<>> DANGER: DO NOT attempt to directly flow LCO2 into a sample bag or minicyl. VPR ALWAYS use a Flash Vaporizer-Pressure Regulator when sampling LCO2 If you have any questions about safe and proper LCO2 sampling, please contact us at labservices@airbornelabs.com. 22C World’s Fair Drive | Somerset, NJ 08873 USA | T: (+1) 732-302-1950 | F: (+1) 732-302-3035 www.airbornelabs.com | ISO/IEC 17025:2005 Accredited Laboratory SOP-S-01 Rev 7 (08/2016) <<>> CO2 Liquid Phase Sampling Using ALI True Blue™ Sampling Bags B. LIQUID PHASE SAMPLING: 2L GAS SAMPLING BAGS (2 BAG SAMPLES REQUIRED) 4) Securely attach the fully warmed VPR to LCO2 source valve. Ensure closure of VPR ball valve at this point. 5) Open the LCO2 source valve & adjust VPR to deliver between 25 - 30 psig. 6) Open the VPR ball valve & purge the system for about 15 sec. 7) While purging - attach a gas sampling bag to the stiff FEP end of the T-fitting. 8) Open the bag’s valve about ¼ - ½ turn MAX & allow it to fill. After it is about ¾ gas filled - detach it & gently press most of the gas out (bag flush). Next, re-attach the bag & allow it to fill again to about 2/3 (66%) full MAX*. (SEE EXHIBIT 2) *WARNING: Overfilling may cause sample bag rupture during air transport! 9) Close the bag valve - ID label it (SEE EXHIBIT 3), add the PTFE port cap & store it in the shipping case (upper tray) (SEE EXHIBIT 4) 10) Repeat steps #7 - 9 using 2nd bag. Keep the gas flowing for minicyl sampling during steps #11-13. 22C World’s Fair Drive | Somerset, NJ 08873 USA | T: (+1) 732-302-1950 | F: (+1) 732-302-3035 www.airbornelabs.com | ISO/IEC 17025:2005 Accredited Laboratory SOP-S-01 Rev 7 (08/2016) <<>> CO2 Liquid Phase Sampling Using ALI True Blue™ Sampling Bags CAUTION: Perform sampling in a well-ventilated area. Wear all needed safety equipment. Exhibit 1 Exhibit 2 2/3 Capacity filled MAX. Exhibit 3 Exhibit 4 22C World’s Fair Drive | Somerset, NJ 08873 USA | T: (+1) 732-302-1950 | F: (+1) 732-302-3035 www.airbornelabs.com | ISO/IEC 17025:2005 Accredited Laboratory SOP-S-01 Rev 7 (08/2016) <<>> CO2 Liquid Phase Sampling Using ALI Minicyls C. LIQUID PHASE SAMPLING: 75 – 300 CC MINICYLS (2 MINICYL SAMPLES REQUIRED IF AN H2O TEST IS NEEDED) 11) While still flushing the VPR, detach T-fitting from VPR & attach the short ST-1 transfer line. Purge the system for about 15 seconds. (SEE EXHIBIT 5) 12) Securely attach minicyl’s check valve inlet side to ST-1. Close ball valve and adjust VPR pressure to 25 - 30 psig. Next, open the ball valve and FULLY open the minicyl’s inlet valve - then outlet valve IN THAT ORDER. 13) Allow the minicyl to purge for about 5 min – then close the minicyl outlet valve - wait 5 sec - then close its inlet valve IN THAT ORDER. Next, close the VPR ball valve. (SEE EXHIBIT 6) 14) Detach minicyl from ST-1, ID label it, return end caps & store in the shipping case. If a 2nd minicyl was included for H2O testing, open VPR ball valve and repeat steps #12 – 13. (SEE EXHIBITS 7 & 8) 15) Shut off LCO2 source valve - open VPR ball valve - allow VPR to depressurize - unplug VPR & detach. Return the ST-1 into shipping case. Re-cap the VPR & after cooling, return VPR to its storage container. 22C World’s Fair Drive | Somerset, NJ 08873 USA | T: (+1) 732-302-1950 | F: (+1) 732-302-3035 www.airbornelabs.com | ISO/IEC 17025:2005 Accredited Laboratory SOP-S-01 Rev 7 (08/2016) <<>> CO2 Liquid Phase Sampling Using ALI Minicyls CAUTION: Perform sampling in a well-ventilated area. Wear all needed safety equipment. Important: Perform a 5 Minute Purge before Filling! Exhibit 5 Exhibit 6 Exhibit 7 Exhibit 8 22C World’s Fair Drive | Somerset, NJ 08873 USA | T: (+1) 732-302-1950 | F: (+1) 732-302-3035 www.airbornelabs.com | ISO/IEC 17025:2005 Accredited Laboratory SOP-S-01 Rev 7 (08/2016) <<>> CO2 Liquid Phase Sampling Snow Generation & NVR Can Sampling D. SNOW from LIQUID PHASE: USING SNOWQUIK™ SNOW MAKER (MINIMUM 1 SAMPLE REQUIRED) Warning: Make sure the snow device is pointing away from staff & local objects during snow generation! 16) Inspect the NVR can’s shiny interior for cleanliness. Next, weigh the empty (lidless) NVR can with an appropriate balance on a level surface (ex. DS-2kg). Record this “empty” wt (g) on the can’s ID tag. (SEE EXHIBIT 9) 17) Follow all pictorial instructions for attaching a SnowQuik™ snowmaking device to the LCO2 source valve + hardware purging (SEE EXHIBIT 10) 18) Open the LCO2 source valve & follow the instructions (SEE EXHIBIT 10) for snow bag filling. After filling, close the LCO2 source valve & allow the snow device to de-pressurize. 19) After de-pressurization, follow instructions for transferring the snow sample into the kit’s pre-weighed 1L NVR can (1/2 – ¾ NVR can filling is desired). Next, Quickly reweigh the kit’s lidless, snow-filled NVR can (g). Record this “filled” wt on the sample ID tag. Subtract the “filled” wt from the “empty” wt & record this net snow sample wt (g) on the ID tag (Note: a minimum of 200 g net wt of snow is required). (SEE EXHIBIT 11) 20) Clip on the kit’s NVR can lid & allow all snow to fully evaporate (sublime) before returning it into the shipping case. (SEE EXHIBITS #12 & 13) Warning: DO NOT re-pack a snow-filled NVR can into the shipping case before all snow has evaporated. An ALI IR (IRL-1) lamp can be used to speed up snow evaporation. DO NOT use any type of hot plate or oven to speed up snow evaporation. Without an IR lamp snow evaporation typically takes about 2 hrs. 22C World’s Fair Drive | Somerset, NJ 08873 USA | T: (+1) 732-302-1950 | F: (+1) 732-302-3035 www.airbornelabs.com | ISO/IEC 17025:2005 Accredited Laboratory SOP-S-01 Rev 7 (08/2016) <<>> CO2 Liquid Phase Sampling Snow Generation & NVR Can Sampling CAUTION: Perform Snow Evaporating steps in a well-ventilated area. Do not use hot plates or ovens to speed up the snow evaporating process. 1. Place balance on a flat, level surface. Next, zero the balance before adding the NVR can. Refer to Snow-Sampling Instructions (Exhibit 10) on next page Quickly reweigh after snow transfer and calculate the weight of snow obtained. 2. Record weight of empty NVR can. Exhibit 9 Exhibit 11 WARNING: DO NOT use hot plates or ovens to speed up the snow evaporating process. After evaporation, examine can interior for NVR/NVOR and record results. Exhibit 12 Exhibit 13 22C World’s Fair Drive | Somerset, NJ 08873 USA | T: (+1) 732-302-1950 | F: (+1) 732-302-3035 www.airbornelabs.com | ISO/IEC 17025:2005 Accredited Laboratory SOP-S-01 Rev 7 (08/2016) <<>> Exhibit 10 Snow Sampling using SnowQuik™ Equipment CAUTION: Perform Snow-Making steps in a well-ventilated area. Wear Cryo-Safety Gloves & all other needed safety gear. ST-6 Sulfinert & PTFE ST-6 Sulfinert & PTFE passivated, high pressure passivated, high pressure flexible tubing (6’ approx. flexible tubing (6’ approx. 2M) 2M) 1. Porous particle- free synthetic Snow Bag 2. 3. 4. 5. 6. 7. 8. Inspect the Cone & Snow Bags for cleanliness then attach to the LCO2 Source Valve using an appropriate mating fitting. The Snow Bag should not be attached at this point. Slightly open the LCO2 Source Valve to gently flush the Snow Cone for about 10 sec., then close the LCO2 Source Valve. Slide the Snow Bag over the Cone & secure it using the Ring-lok. Fully open the LCO2 Source Valve to start a vigorous CO2 flow & snow generation. During this step, shake & tap the sides of the Snow Cone / line & bags to prevent or break up any snow blockage. Wear cryo-safety gloves during sampling. When the Snow Bag is full (about 1 minute fill time), shut off the LCO2 Source Valve & allow the system to de-pressurize. Immediately transfer the snow sample into a pre-weighed empty No-Haz kit 1L NVR can until this can is filled between ½ to ¾ full. Obtain the filled can wt. (g), net snow wt. (g) and record on ID tag. Next, refer back to Exhibits 11-13. Remove any residual snow & store the Snow Bag in a clean storage container. Wipe off any surface moisture from the Cone assembly & store it in a clean container. Note: Replace Snow Bags if they become soiled or wear to the extent that artifact fibers are generated. 22C World’s Fair Drive | Somerset, NJ 08873 USA | T: (+1) 732-302-1950 | F: (+1) 732-302-3035 www.airbornelabs.com | ISO/IEC 17025:2005 Accredited Laboratory SOP-S-01 Rev 7 (08/2016) <<>> No-Haz LCO2 Gas Sampling Kit™ Return Shipping Instructions E. REPACKING & RETURN SHIPMENT 1) Fill out the “Analysis Authorization” form & store it within the mesh pouch of the case. Please note that ALI cannot perform any analytical testing unless this form is completed and returned with the kit. 2) Return all equipment into their assigned compartments within the shipping case. Review the check list to ensure all kit items have been repacked. OPTION A: PRE-PAID ROUND TRIP ALI - FEDEX SHIPMENT If “Pre-Paid Round Trip Shipping” was selected with your ALI Sales Representative, insert the ALI Commercial Invoice into the supplied, clear FedEx pouch and attach this pouch to the shipping case handle. Affix your pre- printed FedEx shipping - waybill label to the outside of this FedEx pouch (SEE EXHIBIT 14). Call FedEx for pick up (labeled as a non-hazmat shipment) & alert ALI at shipping@airbornelabs.com of your tracking number. OPTION B: RETURN SHIPMENT USING YOUR COMPANY’S FEDEX ACCT If “One-Way Shipping” was selected and you choose to return ship using your own FedEx account, insert the ALI Commercial Invoice into the supplied, clear FedEx pouch and attach this pouch to the shipping case handle. Next, fill in the supplied FedEx “International Air Waybill” and insert it into this pouch. (SEE EXHIBIT 15). Call FedEx for pick up (labeled as a non-hazmat shipment) and alert ALI at shipping@airbornelabs.com of your tracking number. 22C World’s Fair Drive | Somerset, NJ 08873 USA | T: (+1) 732-302-1950 | F: (+1) 732-302-3035 www.airbornelabs.com | ISO/IEC 17025:2005 Accredited Laboratory SOP-S-01 Rev 7 (08/2016) <<>> No-Haz LCO2 Sampling Kit™ Return Shipping Instructions E. REPACKING & RETURN SHIPMENT OPTION C: RETURN SHIPMENT – ALI APPROVED NON-FEDEX COURIER If “One-Way Shipping” was selected with your ALI Sales Representative and you choose to return ship with an non-FedEx, ALI approved courier* - reference EXHIBIT 16 for detailed return shipment information when filling out your courier’s paperwork. Insert the ALI Commercial Invoice & courier’s waybill into the clear pouch and attach this pouch to the shipping case handle. Call your courier for pick up (labeled as a non-hazmat shipment) & alert ALI at shipping@airbornelabs.com of your tracking number. *NOTE: If FedEx cannot be used, ALI must approve any courier requested for your ALI No-Haz Kit return. WARNING: If you select a courier that is NOT approved by ALI, your shipment may be delayed by Customs, resulting in additional fees! If you have any questions about proper return shipping, or would like a UPS, DHL, or TNT completed RETURN WAYBILL example - please contact us at shipping@airbornelabs.com 22C World’s Fair Drive | Somerset, NJ 08873 USA | T: (+1) 732-302-1950 | F: (+1) 732-302-3035 www.airbornelabs.com | ISO/IEC 17025:2005 Accredited Laboratory SOP-S-01 Rev 7 (08/2016) <<>> No-Haz Sampling Kit™ Return Shipping Instructions CO2 samples taken in standard ALI No-Haz Sampling Kits™ can be properly returned to ALI as non-dangerous (non-hazardous) goods. It is important to properly describe these sample kits in order to avoid confusion by the carrier and mislabeling of these kits on courier shipping paperwork. Mislabeling your courier paperwork will result in sample rejection, shipment delays, and ultimately additional costs in sample re-shipment. A non-compressed, non-hazardous CO2 sample must be properly and precisely described in the “Shipment Information” section as: “NON-HAZARDOUS INDUSTRIAL SAMPLE OF NO COMMERCIAL VALUE” To avoid confusion, DO NOT describe these samples as “CO2 Samples” in courier paperwork as it will be assumed that the samples are hazardous, compressed CO2– which they are not. “CO2 SAMPLES” Please contact us at shipping@airbornelabs.com if you have any questions about returning this sample-filled kit to ALI. 22C World’s Fair Drive | Somerset, NJ 08873 USA | T: (+1) 732-302-1950 | F: (+1) 732-302-3035 www.airbornelabs.com | ISO/IEC 17025:2005 Accredited Laboratory SOP-S-01 Rev 7 (08/2016) <<>> Exhibit 14 (Option A) PRE-PAID ROUND TRIP ALI - FEDEX SHIPMENT ALI SUPPLIED FEDEX RETURN ADDRESS – WAYBILL STICKER WITH YOUR INFORMATION SHIPPING DEPARTMENT AIRBORNE LABS INTERNATIONAL INC. 22C WORLD’S FAIR DRIVE SOMERSET, NJ 08873 USA WARNING: DO NOT affix a FedEx Sticker or any other stickers to outside of shipping case! ATTACH POUCH TO HANDLE INSERT COMMERCIAL INVOICE INSIDE THIS POUCH COMMERCIAL INVOICE IMPORTANT : AFFIX FEDEX RETURN ADDRESS –WAYBILL STICKER TO OUTSIDE OF THIS POUCH AFFIX (2x) Security Tags If you have any questions about proper return shipping, please contact us at shipping@airbornelabs.com 22C World’s Fair Drive | Somerset, NJ 08873 USA | T: (+1) 732-302-1950 | F: (+1) 732-302-3035 www.airbornelabs.com | ISO/IEC 17025:2005 Accredited Laboratory SOP-S-01 Rev 7 (08/2016) <<>> RETURN SHIPMENT ON YOUR COMPANY’S FEDEX ACCT Exhibit 15 (Option B) MM/DD/YY YOUR SHIPPING ACCOUNT # YOUR NAME YOUR PHONE # YOUR COMPANY YOUR ADDRESS 1 YOUR ADDRESS 2 YOUR CITY YOUR STATE / PROVINCE Choose how quickly you want your shipment to arrive. YOUR COUNTRY YOUR ZIP ATTN: LAB (732) 302-1950 CASE AIRBORNE LABS INTERNATIONAL INC. 22C WORLD’S FAIR DRIVE SOMERSET NJ USA 08873 QTY, Weight, and Dimensions dependent on your shipment. 223737276 1 21 / 17 / 9 PICK YOUR PAYMENT OPTION ENTER HERE ALL ITEMS AS LISTED ON YOUR COMMERCIAL INVOICE Also include description: “NON-HAZARDOUS INDUSTRIAL SAMPLE OF NO COMMERCIAL VALUE” A B C 17.0 WARNING: DO NOT affix any stickers to outside of shipping case! YOUR ALI INVOICE # D TOTAL USD A. Harmonized Codes are unique per Country. Refer to your Invoice for clarification. B. Country of Manufacture for all Rental Kits is the USA. C. Refer to your Commercial Invoice included in your shipment for all “Value for Customs”. D. Total declared value for Carriage is $0 FEDEX WAYBILL COMMERCIAL INVOICE ATTACH POUCH TO HANDLE INSERT COMMERCIAL INVOICE & COMPLETED FEDEX WAYBILL INSIDE OF THIS POUCH AFFIX (2x) Security Tags <<>> Exhibit 16 (Option C) RETURN SHIPPING WITH YOUR ALI APPROVED NON-FEDEX COURIER SEND TO: AIRBORNE LABS INTERNATIONAL 22C WORLD’S FAIR DRIVE SOMERSET, NJ 08873 USA ATTN: LAB PH: 1-732-302-1950 EIN: 223737276 WARNING: DO NOT affix any stickers to outside of shipping case! SHIPMENT INFO: SHIPMENT QTY, WEIGHT, & DIMENSIONS ARE DEPENDENT ON YOUR SHIPMENT REFER TO YOUR COMMERCIAL INVOICE WHEN LISTING ALL ITEMS INCLUDED IN YOUR SHIPMENT YOU MUST INCLUDE IN YOUR WAYBILL DESCRIPTION: “NON- HAZARDOUS INDUSTRIAL SAMPLE OF NO COMMERCIAL VALUE” INCLUDE YOUR ALI INVOICE # AS YOUR INTERNAL BILLING REFERENCE AFFIX (2x) Security Tags WAYBILL COMMERCIAL INVOICE ATTACH POUCH TO HANDLE INSERT COMMERCIAL INVOICE & COMPLETED WAYBILL INSIDE OF THIS POUCH WARNING: If you select a courier that is NOT approved by ALI, your shipment may be delayed by Customs, resulting in additional fees! If you have any questions about proper return shipping, or would like a UPS, DHL, or TNT completed RETURN WAYBILL example - please contact us at shipping@airbornelabs.com 22C World’s Fair Drive | Somerset, NJ 08873 USA | T: (+1) 732-302-1950 | F: (+1) 732-302-3035 www.airbornelabs.com | ISO/IEC 17025:2005 Accredited Laboratory SOP-S-01 Rev 7 (08/2016) <<>> EXAMPLE: Refer to www.airbornelabs.com/analytical-laboratory-services-co2 for the most current FedEx letter. <<>> No-Haz LCO2 Sampling Kit Instructional Videos For additional sampling support using please visit ALI’s YouTube Channel at the links below: VPR - Sample Bag Sampling: English: http://goo.gl/l6nTLe VPR - Minicyl Sampling: English: http://goo.gl/qMZnCI French: http://goo.gl/551E2D SnowQuik™ Snow Sampling English: http://goo.gl/aCILEk 22C World’s Fair Drive | Somerset, NJ 08873 USA | T: (+1) 732-302-1950 | F: (+1) 732-302-3035 www.airbornelabs.com | ISO/IEC 17025:2005 Accredited Laboratory SOP-S-01 Rev 7 (08/2016) <<>> THESE INSTRUCTIONS & ALL KIT COMPONENTS MUST BE RETURNED THANK YOU! Please Note: Customers will be charged for any damaged or missing kit components √ REMEMBER TO PACK: (2) GAS SAMPLING BAGS (1 or 2) MINICYL(S) AS RECIEVED (1) ST-1 STAINLESS STEEL HOSE (1) SHA T-FITTING (1) NVR SHIPPING CAN WITH LID (1) COMPLETED ANALYSIS AUTHORIZATION FORM (1) SAMPLING INSTRUCTIONS 22C World’s Fair Drive | Somerset, NJ 08873 USA | T: (+1) 732-302-1950 | F: (+1) 732-302-3035 www.airbornelabs.com | ISO/IEC 17025:2005 Accredited Laboratory SOP-S-01 Rev 7 (08/2016) <<>> <<>> Manual - No-Haz CO2 Final ## Provenance - Official: Yes - Source: - Source ID: `phmsa` - SHA-256: `8729b783a7361d710698f56a44a61b60a1662d6ca7a368753cc75c750c4497a6` - Retrieved: 2026-08-20T00:59:31.977Z - Exported: 2026-08-22T21:39:18.394Z - Document slug: `phmsa-interpretation-23-0096` ### Source metadata ```json { "materialSubtype": "interpretation", "interpretationArea": "hazardous_materials", "representation": "full_text_from_official_pdf", "companies": [ "Airborne Labs International, Inc." ], "individuals": [ "Aniyah Volpe" ], "refIds": [ "23-0096" ], "catalogDates": [ "2024-03-27" ], "catalogParts": [ 172, 173 ], "catalogRowCount": 2, "sourceRecordUrls": [ "https://www.phmsa.dot.gov/node/74076" ], "linkedAttachmentUrls": [], "unavailableResponseUrls": [], "duplicateRepresentationUrls": [], "citedSections": [ "172.101", "173.115", "173.115(b)" ], "catalogPageUrls": [ "https://www.phmsa.dot.gov/regulations/title49/section/172101", "https://www.phmsa.dot.gov/regulations/title49/section/173115" ], "pdfUrls": [ "https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/2024-03/230096.pdf" ], "representations": [ { "viewUrl": "https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/2024-03/230096.pdf", "detailUrl": null, "detailHtmlPath": null, "pdfUrl": "https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/2024-03/230096.pdf", "pdfArtifactPath": "data/sources/phmsa-interpretations/23-0096-aa92d4383c.pdf", "pdfArtifactSha256": "47fa859a869ecbd9bd43de0b6082b753050c85861ac7b5abac8ed82b42a4db52", "extractedTextPath": "data/sources/phmsa-interpretations/23-0096-aa92d4383c.v2.txt", "extractedTextSha256": "2d9628aa3776fb38280eb6ebb57e72c9e4653640c71edc8a5a245996f0e2526c", "pageCount": 28, "extractionVersion": 2 } ], "caveat": "Interpretations apply regulations to the facts presented and do not create independently enforceable requirements.", "jurisdiction": "US" } ```