IKI Manufacturing Co., Inc. — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department 400 Seventh St., S.W. Washington, D.C. 20590 OCT 2 0 2000 Ref. No. 00-0163 Mr. Ken Johnson IKI Manufacturing Co., Inc. 116 N. Swift Street Edgerton, WI 53534 Dear Mr. Johnson: This is in response to your letter and subsequent telephone conversation with a member of my staff requesting clarification of the requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) for certain compressed gases. e transported under the proper shipping name "Aerosols" and Specifically, you ask if your products maj whether they may be renamed "Consumer commodity" and reclassed as ORM-D. You state that you have three products. Product A contains 90-95% difluoroethane and 5-10% pentane packaged in 13-ounce metal containers. Product B contains 100% 1,1,1,2- tetrafluoroethane in metal containers with capacities from one ounce to eight ounces. Product C contains 68.5% n-butane and 31.5% propane in metal containers with capacities from one ounce to eight ounces. Your letter contained insufficient information concerning Product A; therefore, we cannot make a determination on whether it meets the definition of an aerosol as provided in $ 171.8. Products B and C do not meet the definition for aerosols and, therefore, the proper shipping name "Aerosols" may not be used. However, Products B and C in containers of not more than 4 fluid ounces capacity may be renamed "Consumer commodity" in accordance with § 173.306 (a) (1) and (h). 173.306 000163#

Page 2With regard to your containers that have a capacity over 4 Programs Administration's Office of Exemptions and Approvals. fluid ounces, you may wish to contact the Research and Special Exemptions are granted on a case-by-case basis to authorize the exemption, DOI E-10232, authorizes ORM-D in accordance with the terms and conditions of the to be offered for transportation as "Consumer commodity," exemption. Procedures for applying for an exemption are set forth in S 107.105 of the HMR. The Office of Exemptions and Approvals may be reached at 202/366-4545. I hope this information is helpful. Please contact us if you need additional assistance. Sincerely, Hothe 2. mithell Hattie I. Mitchell, Chief Regulatory Review and Reinvention Office of Hazardous Materials Standards#

Page 3MANUFACTURING CO., Inc. SPECIALIZED CONTRACT 116 N. SWIFT STREET • EDGERTON, WISCONSIN 53534 AEROSOL PACKAGING PHONE: 608/884-3411 FAX 608/884-4712 Intere May 24, 2000 §173.306 Mr Edward T. Mazzullo 00-0163 Director Of OHMS 400 7" Street SW US DOT/RSPA (DMH-10) Washington, DC 20590-0001 Dear Mr. Mazzullo, I am writing to you concerning a request for clarification of classification for shipment of 7 certain pressurized products from our facility. container with a self closing valve at 13 ounces per container. These containers are further packed into fiberboard boxes as 12 packs for shipping. This product is intended for use as an airbrush propellent. Product B consists of 100% 1,1,1,2-Teträfluoroethane in a container with self closing 2.2 valve with fill weights of 1, 3.5, 6, and 8 ounces. These containers are also further packed into 12 pack fiberboard boxes for shipping. 21 Product C consists of 31.5% Propane and 68.5% n-Butane in a container with self closing ol valve with fill weights of 1, 3.5, 6, and 8 ounces also packed in 12 pack fiberboard boxes. This product and product B are intended for use as signal horn propellents. The question first is whether these products can be classed as aerosols and/or secondly, as such, could they be shipped as consumer commodity (ORM-D)? If not please clarify the proper shipping description for our use and our customer's information. If I can be of further assistance in this matter I can be reached at IKI Manufacturing at (608) 884-7107. Sincerely, en Johnson, Traff cc: Larry Midtbo Jeff Kronforst#