Photographic Solutions, Inc. — Hazardous Materials Safety Interpretation

Page 1400 Seventh Street. S.W. Washington, D.C. 20590 Special Programs Administration APR 2 0 2000 Ref. No. 00-0044 Mr. David M. Stone Photographic Solutions, Inc. President P.o. Box 135 Onset, MA 02558 Dear Mr. Stone: This is in response to your letter and subsequent telephone conversation with a member of my staff requesting clarification of the small quantity exceptions under 49 CFR 173.4. Specifically, you ask whether . 8 ml of "Methanol" contained in a hollow plastic handle which serves as a cleaning swab may be transported under the provisions of $ 173.4. You state that the handle is covered with a sponge material and overwrapped with a soft poly fiber material. You further state that both of these materials would package is then heat package with a camera. A package may be transported under the small quantity exceptions if the material is prepared in accordance with the quantity limits and packaging requirements in § 173.4. Based on the information you submitted, we concur that your package may be transported under the small quantity exceptions, provided all other provisions in S 173.4 are met. The packing of a nonhazardous material in the same package is permitted provided there is no violation of $ 173.21. I hope this information is helpful. Please contact this office if you need additional assistance. Sincerely, Hatle I Mitchell Hattie I. Mitchell, Chief Regulatory Review and Reinvention Office of Hazardous Materials Standards 000044#

Page 2: PHOTOGRAPHIC SOLUTIONS, INC. McIntyre Edward Mazzullo $173.4 Director, Office of Hazardous Materials Standards US Dept. of Transportation / RSPA 00- 0044 400 7% Street SW Washington, DC 20590 24 JAN 2000 Dear Mr. Mazzullo, We intend to have manufactured, a cleaning swab with a hollow plastic handle. This handle will be filled with. 8 ml of methanol which will be contained within the handle. Only with a precisely applied pressure on the handle, can the liquid flow to the ! end of the handle which is covered with a sponge material overwrapped with a soft poly fiber material. Either the sponge or the overwrap of poly would fully absorb the contents of the tube. The entire unit is also completely heat sealed within a 1 mil poly bag, / 5 7x9.6 I am writing to confirm that this product would be exempt from CFR hazardous shipping requirements, for both surface and air, under the small quantity exemption of at least 49CFR173.4(a)(1)(i) or other applicable sections. Could you please provide me with an assessment of whether or not this item, as described and packaged would indeed be exempt from regulation when offered for either air or ground transportation. Thank-you for your assistanes. Sincerely, David M. Stone, Preside i PHOTOGRAPHIC BÓLUTIONS, INC P.O.Box 135 Onset, MA 02558-0135 POST OFFICE BOX 135, ONSET, MA 02558 U.S.A. TEL: (508) 759-2322 FAX: (508) 759-9699 INTERNET: http://www.photosol.com#