CrossNet USA, Inc — Hazardous Materials Safety Interpretation

Page 1• • U.S. Department of Transportation 400 Seventh St., S.W. Research and Washington, D.C. 20590 Special Programs Administration FEB - 5 2002 Ms. Cindy Seki CrossNet USA, Inc. Ref. No. 02-0012 59 Coburg Road Suite C Eugene, Oregon 97401 Dear Ms. Seki: This responds to your December 7, 2001 letter requesting clarification on § 173.29(b)(2)(ii) under the Hazardous Materials Regulations (HMR; 49 CFR. Parts 171-180). Specifically, you ask if your proposed method of cleaning fuel bottles using a cleaning product, "Slix" satisfies cleaning and purging requirements in § 173.29(b)(2)(ii). You propose to clean and purge fuel bottles that previously contained white gasoline, kerosene, diesel and regular gasoline with a liquid alkaline cleaner, "Slix", in order to satisfy requirements in § 173.29(b)(2)(ii). These fuel bottles are used by hikers and backpackers for cooking on white gasoline stoves. For purposes of the HMR, "cleaned and purged" means no residual hazardous material or vapor remain in a container. The methods used to clean and purge a packaging are intentionally not defined because they vary greatly depending on the nature of the hazardous material and the type of packaging. In some instances, a packaging can be totally emptied of hazardous material, including residue, without undergoing a cleaning process, and may be considered "cleaned and purged". In other instances, an active cleaning process may be necessary to purge a packaging of hazardous residue. We cannot endorse a particular cleaning product or procedure for cleaning and purging. However, the procedure presented in your letter appears to meet the definition of "sufficiently cleaned of residue and purged of vapors to remove any potential hazard" provided any residue remaining in the fuel bottles no longer meets any of the hazard class definitions of the HMR. I hope this answers your inquiry. Sincerely, Delmer F. Billings Chief, Standards Development Office of Hazardous Materials Standards 173.29(6)(2)() 020012#

Page 2CROSSNET USA, INC 59 coburg road, suite c eugene, oregon 97401 tel:541.344.0037•fax:503.212.6884•www.crossnetusa.com December 7, 2001 Boothe Edward Mazzullo Director, Office of Hazardous Material Standards 8173.2962) Gil) 400 7# St. SW US DOT/RSPA (DHM10) Washington, DC 20590-0001 Residue Dear Mr. Mazzullo: Empty My name is Cindy Sekiguchi. I work for an import/export company that geared 02-0012 primarily toward the outdoor industry. I am the project coordinator for developing a the FAA who directed me to you. product line used to clean white gasoline fuel bottles. I contacted Thomas Kenny of This letter is to request clarification of 49CFR part 173.29(b)(2)(ii) that states: "The potential hazard" as it relates specifically to white gasoline fuel bottles. These fuel packaging is sufficiently cleaned of residue and purged of vapors to remove any bottles contain white gasoline, kerosene, diesel and regular gasoline. Hikers and backpackers use the fuel bottles for cooking on white gasoline stoves. After use, the backpacker removes all fuel, leaving behind only a small residue. We are proposing the following method of cleaning the fuel bottle: The proposed cleaner is as follows: MSDS No.: 1861-411N • Product Name: Slix • Manufacturer: Penetone Corporation, 74 Hudson Ave., Tenafly, NJ 07670 General Use: Degreasing (military and aerocraft cleaner) • Product Description: Liquid alkaline cleaner • Generic Ingredients: Water, surfactants and builders (contains no hazardous materials) • Flash Point: None to boiling "All our dreams can come true if we have the courage to pursue them." - Walt Disney NORTH AMERICA-ASIA MARKET RESOURCES#

Page 3The proposed procedure is: • Remove cap from aluminum fuel bottle (approx. 650 ml), pour in 1-2 oz. of cleaner, replace cap, shake bottle, pour out residue. Rinse with warm water. Would the above procedure satisfy the regulations as stated in 49CFR part173.29(b)(2) to sufficiently clean the fuel bottle of residue and purge it of vapors to remove any potential hazard, thereby, making the fuel bottle acceptable for passenger aircraft transportation according to the 49CFR regulations? in order to maintain full compliance with all federal hazardous material regulations, we are requesting a written interpretation specific to the aforementioned product and purpose. I look forward to your reply. Sincerely, CROSSNET USA, INC. ind Cindy Seki Information Design Enclosure "All our dreams can come true if we have the courage to pursue them." - Walt Disney NORTH AMERICA-ASIA MARKET RESOURCES#