AllTransPack, Inc. — Hazardous Materials Safety Interpretation

Page 1= U.S. Department Research and of Transportation 400 Seventh St., S.W. Washington, D.C. 20590 Special Programs Administration JUL 1 1 2002 Mr. Hank Baird Manager Ref. No.: 02-0073 AllTransPack, Inc. P.O. Box 1098 Ashburn, Virginia 20146-1098 Dear Mr. Baird: This responds to your March 7, 2002 letter requesting clarification of the definition for a "chemical kit" under the International Civil Aviation Organization's (ICAO) Technical Instructions and the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if the definition of a "Chemical Kit"' in Special Provision A44 of the ICAO Technical Instructions and Special Provision 15 of Part 172 of the HMR also apply to materials being shipped individually for replacement purposes. Special Provision A44 describes chemical kits as boxes, cases, etc., containing small amounts of one or more compatible dangerous goods that are used for medical, analytical, or testing purposes. Special Provision 15 describes chemical kits as boxes, cases, etc:, containing śmall amounts of various compatible dangerous goods which are used for medical, analytical, or testing purposes and for which exceptions are provided in this subchapter. It is the opinion of this Office that materials being shipped individually for replacement purposes may not be described as chemical kits under these special provisions. Therefore, the replacement material must be described using the appropriate basic description for the material being offered for transportation. I hope this answers your inquiry. Delmer F. Billings Chief, Standards Development Office of Hazardous Materials Standards#

Page 2By: ALLTRANSPACK, INC.; 7038585175; Mar-7-02 9:18; Page 2/2 aP Boothes 172482(5815) al|TransPack, Inc. Definition Hazardous Materals Packaging & Training • General & Specialty Packaging • Warehousing 02-0013 March 07; 2002 Mi. Edward Mazullo/Director, Standards Research and Spécial Programs Administration 4007 Street, SW U.S. Department of Transportation Washington, DC 20590-0001 Dear Mr. Mazullo: This letter is offered as a request for clarification. This request is made by Mr. Hank. Baird, Manager; AllTransPack; Inc.; 21711 Filigree Court, PO Box 1098; Ashburn, VA 20146-1098, Tel: 703-858-5169, Fax: 703-858-5175.. The purpose for this request is 1ö obtain a clarificațion of the definition of the proper shipping name of "Chemical Kit" The Hazardous Materials Regulations state in Special Provision 15 of Part 172:102 that. "Chemical Kits and First Aid Kits are boxes, cases, etc., containing: small amounts of various compatible dangerous goods which are used for medical; aalytical or testing purpöses...". Could the description provided in Special Provision 15 also apply to materials being shipped individually for replacement purposes? For example, if a shipper offered for transportation a complete kit containing fout 100 milliliter plastic bottles of various compatible dangerous goods ałong with compatible non-dangerous goods and instruments in a carrying case and assigned a proper shipping name of "Chemical Kit"; it is clear that the shipper is in accordance with Special. Provision 15. But can the same shipper offer for transportation ond of the 100 millliter plastic bottles of dangerous goods and rightfully apply the proper shipping name as "Chemical Kit"? If so, what exactly would constitute as " '..boxes; cases, etc., " so the shipper can be in full compliance with Special Provision 15? Please review this request and respond at your earliest convenience. If you need more information, please do not hesitate to contact me at 703:858-5169: Please address, any. correspondence to my attention at the address or humbers above Sincerely, Stink Baird Mr. Hank Baird/Manager • FACILITY ADDRESS: Airpack of Virginia, Inc., 217|1 Fillgree Court, Sulte E Ashburt, Virginia 20147 • MAIUNG ADDRESS:. Phone (703) 858-5169 (800) 423-7833 Post Office Bax: 09g: Ashurt Virginia 20146-1098 www.alltranspack.com Fax (703) 858-5175#

Page 3Boothe aP • allTransPack, Inc. Hazardous Materials Packaging & Training • General & Specialty Packaging • Warehousing • March 07, 2002 Mr. Edward Mazullo/Director, Standards Research and Special Programs Administration 400 7* Street, SW U.S. Department of Transportation Washington, DC 20590-0001 Dear Mr. Mazullo: This letter is offered as a request for clarification. This request is made by Mr. Hank Baird, Manager, AllTransPack, Inc., 21711 Filigree Court, PO Box 1098, Ashburn, VA 20146-1098, Tel: 703-858-5169, Fax: 703-858-5175. The purpose for this request is to obtain a clarification of the definition of the proper shipping name of "Chemical Kit". The Hazardous Materials Regulations state in Special Provision 15 of Part 172.102 that "Chemical Kits and First Aid Kits are boxes, cases, etc., containing small amounts of various compatible dangerous goods which are used for medical, analytical or testing purposes... ". Could the description provided in Special Provision 15 also apply to materials being shipped individually for replacement purposes? For example, if a shipper offered for transportation a complete kit containing four 100 milliliter plastic bottles of various compatible dangerous goods along with compatible non-dangerous goods and instruments in a carrying case and assigned a proper shipping name of "Chemical Kit", it is clear that the shipper is in accordance with Special Provision 15. But can the same shipper offer for transportation one of the 100 milliliter plastic bottles of dangerous goods and rightfully apply the proper shipping name as "Chemical Kit"? If so, what exactly would constitute as "...boxes, cases, etc.,..." so the shipper, can.be,in full compliance with Special Provision 15? Please review this request and respond at your earliest convenience. If you need more information, please do not hesitate to contact me at 703-858-5169. Please address any correspondence to my attention at the address or numbers above. Sincerely, Berk Baird Mr. Hank Baird/Manager Airpack of Virginia, Inc., • FACILITY, ADDRESS: 217l| Filigree Court, Suite E Phone (703) 858-5169 Ashburn, Virginia 20147 • MAILING ADDRESS; (800) 423-7833 Post Offiçe Box 1098 Ashburn, Virginla 20146-1098 (703) 858-5175.: www.alitranspack.com#

Page 4Boothe • Beidon 31/8/02 Ref. No. 02-0073 Mr. Edward Mazullo/Director, Standards Research and Special Programs Administration 400 7* Street, SW U.S. Department of Transportation Washington, DC 20590-0001 Mr. Mazullo: This letter is to serve as an addendum to my request for clarification dated March 07, 2002. I erroneously referred to Special Provision 15 of the Hazardous Materials Regulations. I should have referred to Special Provision A44 of the ICAO Technical Instructions. Please note this correction and respond accordingly. Do not hesitate to contact me if you need anything else. Thank you for your time in this manner. Sincerely, Hank Baird/Manager AllTransPack, Inc.#

Page 5March 07, 2002 Mi. Edward Mazullo/Director, Standards Research and Special Programs Administration U.S. Department of Transportation 400 7" Street, SW Washington, DC 20590-0001 Dear Mr. Mazullo: This letter is offered as a request for clarification. This request is made by Mr. Hank Baird, Manager, AllTransPack, Inc., 21711 Filigree Court, PO Box 1098, Ashburn, VA 20146-1098, Tel: 703-858-5169, Fax: 703-858-5175. The purpose for this request is to obtain a clarification of the definition of the proper shipping name of "Chemical Kit'. The Hazardous Materials Regulations state in Special Provision 15 of Part 172.102 that "Chemical Kits and First Aid Kits are boxes, cases, etc., containing small amounts of varlous compatible dangerous goods which are used for medical, analytical or testing purposes...". Could the description provided in Special Provision 15 also apply to materials being shipped individually for replacement purposes? For example, if a shipper offered for transportation a complete kit containing four 100 non-dangerous goods and instruments in a carrying case and assigned a proper shipping name of "Chemical Kit" , it is clear that the shipper is in accordance with Special Provision 15. But can the same shipper offer for transportation one of the 100 milliliter plastic bottles of dangerous goods and rightfully apply the proper shipping name as "Chemical Kit"? If so, what exactly would constitute as "...boxes, cases, etc.,..." so the shipper can be in full compliance with Special Provision 15? Please review this request and respond at your earliest convenience. If you need more information, please do not hesitate to contact me at 703-858-5169. Please address any correspondence to my attention at the address or numbers above. Sincerely, Mr. Hank Baird/Manager Airpack of Virginia, Inc.#