Innowave Incorporated — Hazardous Materials Safety Interpretation

Page 1f Transportatio S. Departmen 400 Seventh Street, S.W. Washington, D.C. Research and 20590 Special Programs Administration MAR 3 0 2000 Mr. Robert Haney Innowave Incorporated Ref. No. 00-0075 3201 Farnam Street Omaha, Nebraska 68131 Dear Mr. Haney: This is in response to your letter dated March 1, 2000, and subsequent telephone conversation with Eric Nelson of our staff regarding the proper hazard class or division for your products, FreshCUP BioCleansing Solutions, under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Based on subsequent information sent to this Office and additional telephone conversations with Mr. Nelson, this Office can not determine the hazard class or division for your products. However, it is possible that these products may meet the definition of a corrosive liquid, and therefore subject to the HMR. We understand that these products are to be imported into the United States from Israel. Under § 173.22 of the HMR, it is the shipper's responsibility to properly class a hazardous material, and it may be necessary to test these products to determine their proper hazard class or division. As provided by § 171.12, it is the importer's responsibility to furnish to the shipper and forwarding agent at the place of entry into the United States, complete information as to the requirements of the HMR. In addition to the requirements of the HMR, international air and vessel shipments of hazardous materials are subject to the provisions of the International Civil Aviation Organization's Technical Instructions and/or the International Maritime Dangerous Goods Code. I hope this satisfies your request. Sincerely, Delmer F. Billings Chief, Standards Development Office of Hazardous Materials Standards 000075 173,22#

Page 2* o The Highest Standards... The Safest Drinking Water innowave® A MUTUAL OF OMAHA SUBSIDIARY nelson March 1, 2000 $173.22 00-0075 Office of Hazardous Materials Standards, Ms. Gail P. Mayhew U.S.Department of Transportation Research & Special Programs Administration 400 Seventh Street, S.W. Room 8407 Washington, D.C. 20590 RE: FreshCUP Project - Biocleansing Solution Dear Ms. Mayhew: maha. We are a subsidiary of the Mutual ef Omaha Insurance Companies. We are hoping that you ca By way of introduction, innowave incorporated is a water purification company based out of sint usael calied the fresh ofthe regulatory issues associated with a new product we are going to impor for that solution. We are trying to make sure there are no DOT regulations that we have overlooked The FreshCUP utilizes a BioCleansing Solution, and I am enclosing a copy of the MSDS sheets and want to make sure there are no outstanding regulatory concerns. concerning the transport of the soap solution. We eventually plan to sell this product in all of the 50 states special permits, procedures, labels, etc. required for the transport of the FreshCUP detergent. If we do not We wouid very much appreciate a written statement from your office as to whether there are any hear back from your office by April I, 2000, we will assume that we have met all of the applicatle standards. hesitate to contact me should you have any questions. Thanks for your help. I look forward to receiving your response. In the meantime, please don't Very truly yours, Bat tang Bob Haney Product Manager Enclosure Ethirt. Hanry E mutrilotomcha.com 351 www.innowave.com#