Hazmateam, Inc. — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department Washington, D.C.. Research and pecial Program dministratio JUN 6 2000 Ref. No. 00-0108 Mr. Paul J. Dambek 24 Mystic Hill Road Hazmateam, Inc. Mystic, CT 06355 Dear Mr. Dambek: This is in response to your letter requesting clarification under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) pertaining to the use of the entry "Polyester resin kit," UN3269. Specifically, you ask whether your material and packaging meets the requirements under Special Provision 40 and whether your inner packaging consisting of two separate reservoirs would be considered two separate inner receptacles. You state that the kit contains two separate materials consisting of a methyl methacrylate adhesive which is a Class 3, Packing Group III and dibenzoyl peroxide, type E, PG II which is an organic peroxide activator in solid form. Provided the organic peroxide does not require temperature control, its maximum quantity does not exceed one pound per inner packaging and the two materials will not interact dangerously in the event of leakage, your material meets the requirements for Special Provision 40. With regard to the packaging you sent us, it is the opinion of this Office that it is two separate receptacles which are attached. Provided the inner receptacles are placed in an outer specification package as specified in § 173.225, your packaging is authorized for the entry "Polyester resin kit." I hope this information is helpful. Please contact this office if you need additional assistance. Sincerely, Halte a Mithe l Hattie I. Mitchell, Chief Regulatory Review and Reinvention Office of Hazardous Materials Standards 172.101(p) 000108#

Page 2S172.101 (P) HAZMATEAM, INC. 24 Mystic Hill Road Polyester Resinkits HAZM Phone: 860-536-2229 Mystic, СТ 06355 Fax: 603-462-2361 00-0108 Director of Office of Hazardous Materials Standards Mr. Edward Mazzullo 00 7" Avenue S.V equest for Clarification Washington, D.C. 20590 April 3, 2000 Dear Mr. Mazzullo: "Polyester Resin Kir. I require two clarifications with regard to the applicability of using the proper shipping name, 1) Do the materials described below meet the requirements of Special Provision 40? Part A - Methyl Methacrylate based adhesive. The material meets the definition of a viscous flammable liquid. The shipping description if shipped separately is: Adhesives, 3, UN 1133, PG III. Part B -Dibenzoyl Peroxide based adhesive activator. The shipping description if shipped separately is: Organic Peroxide (Dibenzoyi Peroxide), type E, (solid, 5.2, UN 3108, PG II 2) Are the inner containers described below allowable for use per Special Provision 40? The 10:1 cartridge (inner container) has the following construction: Cartridge A - Constructed of Polyester and contains 440 ml of Part A described above. Carfridge B - Constructed of Nyion and contains 50 ml of Part B described above. over the nose plugs, followed by the removal disk. Parts A & B are filled into their respective The nose plugs are inserted into the respective cartridge. The retaining nut is then screwed the cartridge, below the piston, is crimped. The crimp prevents the contents of the cartridges cartridge through the bottom and sealed with the respective piston. Once filled, the base of from pushing the piston out. The end user removes the removal disk, retaining nut and nose plugs, then attaches a mixing tip. Parts A and B mix together in the mixing tip after being pushed out of the cartridge with a mixing gun.#

Page 3This particular tube, the 10:1 cartridge, has passed the internal pressure test, described in 49 fibreboard box has passed all of the required UN specification packaging tests which are CFR 173.27 (c). In addition, a combination package of twelve 10:1 cartridges inside a A fully assembled, empty, 10:1 cartridges along with a diagram are included with this letter. Should you have questions, please do not hesitate to contact me at 860-536-2229 or via e-mail, dambek@earthlink.net. Your assistance is greatly appreciated. Sincerely, Fand Dambt Paul J. Dambek#