Morgan Schaffer System — Hazardous Materials Safety Interpretation

Page 1: U.S. Department 400 Seventh St., S.W. of Transportation Washington, D.C. 20590 Research and pecial Program ministratic OCT 1 3 2000 Mr. Eric Valentine Ref. No. 00-0188 Customer Support & Training Morgan Schaffer System 5110 Courtrai Avenue Montreal, Quebec CANADA H3W 1A7 Dear Mr. Valentine: This is in response to your June 6, 2000 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) as they relate to the domestic and international transportation of gas analytical instruments, identified as a TFGA-P200 Portable Fault Gas Analyzer and a PHA-1000 Portable Hydrogen Analyzer, by passenger aircraft. You state that a DOT 3E1800 cylinder with a capacity of 300 ml is installed inside the instrument housing. The instrument and a DOT 4B240 cylinder with a capacity of 900 ml are packed in an outer packaging. Your questions are paraphrased and answered in the order posed in your letter. Questions: May the package containing the instrument and cylinders be offered for transportation by passenger aircraft if the DOT 3E1800 cylinder is filled with helium and the DOT 4B240 cylinder is filled with a mixture of 98.6% air and 0.2% each of hydrogen, methane, ethane, ethylene, acetylene, carbon dioxide and carbon monoxide? Similarly, may the package be offered for transportation by passenger aircraft if the DOT-3E1800 cylinder is filled with nitrogen and the DOT 4B240 cylinder is filled with a mixture of 99% air and 1% hydrogen? Answer: The answer to both questions is yes. A DOT 3E cylinder is authorized for helium and nitrogen by § 173.302. A DOT 4B cylinder is authorized for a nonflammable compressed gas mixture by § 173.302 (a). When offered for transportation, the valve on the DOT 3E cylinder installed inside the instrument must be tightly closed. See §§ 173.27, 173.34 and 173.301. The package must be declared as a hazardous material shipment. Helium, nitrogen and the described gas mixtures would be classified as Division 2.2 (nonflammable gas). The § 172.101 Hazardous Materials Table authorizes a maximum net weight, in one package, of a Division 2.2 material of up to 75 kg for transportation by passenger aircraft. Each package must be labeled with a Division 2.2 label and properly marked with the proper shipping name and identification number of the hazardous materials as required by §§ 172.400 and 172.301 respectively. In 112101 000188#

Page 2addition, each shipment must be accompanied by a shipping paper containing a shipper's certification that the hazardous materials have been properly described. packed, marked, labeled and are in proper condition for transportation. See 49 CFR172.202 and 172.204. I hope this information is helpful. I have also enclosed some informational material on the HMR. Please contact us if we can be of further assistance. Sincerely, Hotte 2. Mothele Hattie L. Mitchell Chief, Regulatory Review and Reinvention Office of Hazardous Materials Standards Enclosures 2#

Page 3MORGAN MS SCHAFFER SYSTEMS 172107-A analytike Montreal, June 6, 2000. 9173.34 astrima 00 - 0188 Ms. Cheryl West Freeman U.S. Department of Transportation, RSPA Office of Hazardous Materials Technology, DMH-20 Room 8430 Washington, DC 20590-0001 400 Seventh Street S. W. Dear Mrs. Freeman, As per our telephone conversation, I, on behalf of my company, would like to apply for authorization for the etter, from you, provided to us by the original manufacturer of this equipment, MTI Technologies of ransport of compressed gasses in cylinders in the cargo area of passenger aircraft. We previously had such : Fremont CA. Which has since been bought out by Hewlett Packard. We have two portable instruments: -The TFGA-P200 Portable Fault gas Analyzer that contains a 300mL DOT3E1800 cylinder with 1800psi 75Kg -The PHA-1000 Portable Hydrogen Analyzer that contains a 300mL DOT3E1800 cylinder with 1800psi 75Kg 99% air and i.0% of hydrogen. This cylinder is for calibration purposes. max. of high purity Nitrogen. And is checked-in with a 900mL DOT-4B240 cylinder with 160psi max. of We demonstrate and sell this equipment worldwide and we often have questions from airport security. The previous DOT letter usually sufficed but is dated July 1995 and we have been forbidden to board aircraft on occasion because of this. Our equipment can be seen in great detail at www. MorganSchaffer.com. http://www.chem.agilent.com/cag/products/hppsries.html And the original Hewlett Packard equipment can be seen at Thank you for your time, Or, by Email at EValentine@MorganSchaffer.com You may contact me at 514 739 1967 Give Valeto Eric Valentine B.Sc. Customer Support & Training Morgan Schaffer Systems 5110 Courtrai Avenue, Montreal (Quebec), Canada H3W 1A7 • Tel: 514-739-1967 • Fax: 514-739-0434 Website: www.morganschaffer.com#

Page 4------- - I MORGAN MISSTENE SYSTEMS FAX TRANSMISSION SHEET TO: Ms. Chicryl Freeman COMPANY: U.S. Department of Transportation FAX: (2112) 366-3753 DATE: June 2, 2000 FROM: Eric Valentine PAGE 1 OF 1 Dear Mrs. Freeman, As per our icieplione conversation, I, on behalf of my company, would like to apply for authorization for the letter, from you, provided to us by the original manufacturer of this equipment, MTI Teclunologies of transport of compressed gasscs in cylinders in the cargo area of passenger aircraft. We previously had such a Fremont CÁ. Which has since been bought out by Hewlett Packard. We have two portable instruments: max. of higli purity Helium. And is checked-in with a 900mL DOT-4B240 cylinder with 160psi max. of -The TFGA-P200 Porlable Fault gas Analyzer that contains a 300mL DOT3E1800 cylinder with 1800psi nonoxide. This cylinder is for calibration purposes and is quipped with a double valve shutof 8.6% air and 0.2% each of hydrogen, methane, clhane, cllyine, acctylenc, carbon dioxide and carbor -The PHA-1000 Portabic Hydrogen Analyzer that contains a 300mL DOT3E1800 cylinder with 1800psi max. of high purity Nitrogen. And is checked-in with a 900mL DOT-4B240 cylinder with 160psi max. of 99% air and 1.0% of hydrogen. This cylinder is for calibration purposes. We demonstrate and sell this equipment worldwide and we ollen have questions from airport scurity. The previous DOT letter usually sufficed but is dated July 1995 and we have been forbidden to board aircraft on occasion because of this. And urc original Howlet Packard quipment cau be scen al Jur equipment can be seen in great detail at www.MorganSchaffer.com. http://www.chem.agilent.com/cag/products/hppsries.html Thank you for your time, You may conlact me at 514 739 1967 Or, by Email ar EValentine@MosganSchoffer.com Eric Valentine B.Sc. Morgan Schalfor Sysiers Customer Support & Training 5110 de Courtrai Avenue, Montreal (Quebec), Canada /13W IA7 • Tel: 514-739-1967 Fax: 514-739-0434 Website: www.morganschaffer.com#

Page 5Elle Edia View Go Communicator * Morgan Schaffer - Netscape Help Back Forward is Reload Home aSsarch: Biscape. Security ar Baokmalks Ar Location, http://www.morganschafter.com/ et Business Hesour a Lompulers and La Barking and EnCe Directore Search on the Internet a What's Relate Education Esi Entertainmen •MORGAN™ SCHAFFER Transformers - The Inside View Home Transformer Fault Gas Analyzer The Future of Gas Analysis Equipment -onitoring Model TFGA-P200 Diagnostic Tools and Repeatability Unparalleled Speed Lab Services Sampling • Repeatability better than or equal to ASTM D-3612 or Devices IEC 567 Documents Tedinical • Analyzes oil or gas samples • Measures the 7 fault gases separately, in less than 100 & Support Service • Integrated with data management and fault diagnostic seconds Job Offers • Worldwide training and support (optional) software File Download Specifications Analysis Search the Internet for information #Start WordPerfec [EAPUb_C. ISYS Query n Schaffer: Ne#

Page 6• C:ITEMP\carryonDOT. gif (local) - Microsoft Internet Explore Page 1 of 1 at tomporation US Doperment 29039 Special Programs Research and Administration L I 1 1095 #x. Maning thong Mr Analytical. Instrumenta Sales Support Chemist Fremont, California 94538 41262 Christy Street наmати".." Deat Mr. Zhong: this is in response to your appitcation (11477N) of May 5; 1995 to authorise the transport of helium, by passenger aircrest, ix a Xl Specification 3B or 3A cylinder • that 1s part 207,109(o), your application is denied as follows:' ot on analytical instrument. To accordance with An exemption is unnecessary bebause the Mozardous Materials Regulations Materials Table provide for tile transportation of up (49 CER 312-101) Hazardous to 75 ką of hellun in an autholYzed packaging by passenger alteraft. D02 Specification 32 and : ЗА cylinders are anthorized for bettom in 49 CER helium in these cylinders victin the 173-302 an exemption is not recuized to transport instrument described in your application when the cylinder valve is closed dating transportatilf! If you have any questions concerning Jetter, please contact Mrs, Cheryl, Farman at (202) 366-4545. Sincerely. 108ix Associate Administrator tox Alan I. Roberts Hazardous Materiais Safety 7/13/00 1:44:54 PM#