ZAG Industries — Hazardous Materials Safety Interpretation

Page 1• S. Departmen 400 Seventh St., S.W. f Transportatio Washington, D.C. 20590 Research and Special Programs Administration OCT 27 2000 Mr. Miki Birnbaum Ref. No. 00-0271 ZAG Industries 19 Hamelacha Street New Industrial Zone Rosh Hayim 48091 ISRAEL Dear Mr. Birbaum: This is in response to your September 27, 2000 letter requesting clarification on the requirements for outside packagings for cylinders under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if there are testing requirements applicable to outside packagings for the shipment of certain cylinders. Section 173.301(k) requires that DOT Specification 2P, 2Q, 3E, 3HT, 4BA spherical type, 4D, 4DA, 4DS, 9,39, 40, and 41 cylinders are shipped in a strong outside packaging that adequately provides protection for the cylinder. Unless the cylinders are equipped with a protective neck collar or neck ring, the outside packaging must provide protection from accidental functioning and damage. A strong outside package is defined by § 171.8 to be the outermost enclosure which provides protection against the unintentional release of its contents under conditions normally encountered in transportation. There are no specific testing requirements for strong outside packagings. I hope this satisfies your request. Sincerely, Delmer F. Billings Chief, Standards Development Office of Hazardous Materials Standards 173,301 000271#

Page 2Nelson 8|73.301 (k) Date: 10 September, 2000 Com pressed Gases 00 - 0271 To: DOT From: Miki Birnbaum - ZAG Ref: Testing plastic boxes for shipping small CO, containers Dear Sir/Lady I am attaching some details and photos of the CO2 containers and the foldable shipping box. Please advise your recommended testing procedure and transportation requirements for the plastic boxes in which holds 3x6=18 containers and will be displayed in the store and transported (full) to the sale points and back (empty) to the filling plant (transportation by trucks). Containers The containers are high pressure and drop proven for home use. Material: Aluminum Dia.: 60 mm Length: 365mm Weigh (full) 1.25 Kg Weight (empty) 0.66 Kg Plastic box Length: 400 mm Width: 200mm Height: 400 mm Weight (empty) 5 Kg Loaded weight 27.5 Kg Many thanks in advance Miki Birnbaum - Engineer#