Enefco International, LTD. — Hazardous Materials Safety Interpretation

Page 1J.S. Department Research and of Transportatior 400 Seventh St., S.W. Washington, D.C. 20590 Special Programs Administration DEC: 172001 Mr. James F. Timmins Enefco International, LTD. Ref. No. 01-0289 1130 Minot Ave. Auburn, ME 04211-1120 Dear Mr. Timmins: This is in response to your letter dated November 2, 2001 regarding the applicability of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) to cleaning cards, pens, and wipes that contain 3 ml or less of isopropyl alcohol. You state that your products contain no free flowing alcohol. For the proper shipping name "Solids containing flammable liquids, n.o.s.," the Hazardous Materials Table refers you to special provision 47. Special provision 47 excepts from the HMR sealed packets that contain less than 10 ml of a flammable liquid in Packing Group II or III when the liquid is completely absorbed onto a solid material. Based on the information that you provided in your letter, it is the opinion of this Office that your cleaning cards, pens, and wipes are not subject to the requirements of the HMR. I hope this information is helpful. Sincerely, Edward. Mozal Edward T. Mazzullo Director, Office of Hazardous Materials Standards 010289 173.120#

Page 2FROM : ENEFCO INTERNATIONAL TO : 12023663012 2001,11-02 01:34PM #343 P.Ø1/Ø1 Betts $173.120 classification ENEFCO INTERNATIONAL, LTD. 01-0287 James F. Timmins Enetco International, LTD. 1130 Minot Ave. / PO Box 1120 Auburn, ME 04211-1120 Nov. 02, 2001 Altn.: Edward Mazzullo US DOT / RSPA (DHM-10) 400 7* Strect SW Washington, DC 20590 Dear Mr. Mazzullo, I would like to reyuest an Interpretation 1 eller regarding the solids containing flammable liguids under 172.101 UN 3175 Packing group II Special provision 47. If this could be addressed to me at the above address I would grcally appreciate it. We are a manufacturer of cleaning cards, pens, and wipes that comlain 3 ml or loss of Isopropyl Alcohol. The cleaning cards and wipes are saturated and pouched in a foil pouch. The card and wipes absorb the Isopropyl Alcohol complicly. The pens have a fell within the barrel that is saturated like you would a marker. In all thesc products there is no free flowing alcohol. 1 would like to extend my appreciation for your holp in this matter. I also would acknowledge that Miss H. Singh of the Harmal lixemption Offico, and Arthur Pollack of the Rogulations Office were extremely helpful in directing me to your office. ase Timi Enefco International, LTD 1130 MINOT AVENUE • PO BOX 1120 • AUBURN ME 04211-1120 207-784-6933 • FAX 207-782-7303#