Micro Care Corporation — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation 400 Seventh St., S.W. Washington, D.C. 20590 Research and Special Programs Administration MAY 29 2001 Mr. Jay S. Tourigny Ref. No. 01-0112 Vice President, Operations Micro Care Corporation 595 John Downey Drive New Britain, CT 06051 Dear Mr. Tourigny: This responds to your May 2, 2001 letter requesting clarification on the classification of your aeros... 21 ar cleaner under the Hazardous Materials Regulations (HMR; (HMR; CFR Parts Parts Specifically; you sir:% si7:x6 ask whether your "RX-11" aerosol cleaner may be classed as a "Consumer Commodity, ORM-D.....* According to your letter, you have determined the proper shipping description of your cleaner, fRX-:s0as2 cat: 11", to be "Aerosol, Class 2.2, UN 1950." In addition, you state that your product meets the limited quantity packaging provisions under § 173.306(a)(3), as well as the consumer commodity provisions. in § 173.306(h) of the HMR. This cleaner will be distributed. and sold for use by individuals trained as professional refrigeration service technicians. The definition of a consumer commodity includes hazardous materials that are suitable for retail sale to consumers for purposes of personal care or household use but that may, in fact, be used in some other fashion. Based on the information provided in your letter, it is the opinion of this Office that your aerosol cleaner may be classed as a Consumer Commodity, ORM-D, material under the HMR. I hope this satisfies your inquiry. Sincerely, Transportation Regulations Specialist Office of Hazardous Materials Transportation 010112 173,306#

Page 2Boothe MICRO CARE 3173.306(9)(3) Consumer Commodity: MICRO CARE CORPORATION 01-0112 May 2, 2001 Mr. Edward T. Mazzullo Director, Office of Hazardous Materials Standards U.S. DOT/RSPA (DHM-10) 400 7' Street S.W. Washington, D.C. 20590-0001 Dear Mr. Mazzullo: I am writing to request written DOT confirmation that we are correct in shipping use by field service technicians in the repair and maintenance of refrigeration equipment. "RX-11" is an Aerosol, Class 2.2, UN1950 under the Hazardous Materials Regulation (49 CFR Parts 171-180), with the following technical details: 1. Packaging: Metal, DOT 2Q specification aerosol can, filled in compliance with all conditions listed in 173.306(a)(3). Filled containers are packaged and sealed in outside packaging consisting of either a 200# test corrugated fiberboard carton, or a heavy duty combination corrugated fiberboard/thermal shrink plastic film. 2. Propellant: Non flammable liquid propellant. 3. Active Ingredient: The active ingredient is a non flammable cleaning solvent, that when not packaged in an aerosol can, is classified as a non hazardous, non regulated, liquid cleaning compound. Although we are confident that the "RX-11" package meets the definition of Consumer Commodity ORM-D as defined in 171.8 and provided in 173.306(a)(3) and professional refrigeration service technicians. This distinction has our shipping 173.306(h), it will be distributed and sold for consumption by individuals trained as people requesting written D.O.T. confirmation that the "RX-11" qualifies for shipment as a "Consumer Commodity, ORM-D". 34 Ronzo Road • Bristol, Connecticut 06010 • (860) 585-7912 • FAX (860) 585-7378 • 800-638-0125 www.microcare.com#

Page 3Please respond to my attention either by e-mail at: jayt@microcare.com, or via postal service letter at: Jay S. Tourigny Micro Care Corporation 595 John Downey Drive New Britain, CT 06051 a you shoute have arm destions reading thie as ernal me at the above Thank you for you assistance Sincerely, vice President, Operations Micro Care Corporation#