SENSIDYNE — Hazardous Materials Safety Interpretation

Page 1of Transportatior J.S. Departmeni 400 Seventh St., S.W. Research and Washington, D.C. 20590 Special Programs dministration FEB | 3 2003 Mr. Ron Roberson Ref. No.: 02-0092 Corporate Industrial Hygienist & Technical Manage SENSIDYNE 16333 Bay Vista Drive Clearwater, FL 3376088 Dear Mr. Roberson: This responds to your letter regarding the small quantity exceptions under the Hazardous Materials Regulations (HMR: 49 CFR Parts 171-180), as they apply "smoke tubes" sold by your company. We apologize for the delay in responding and hope it has not caused any inconvenience. According to your letter, the smoke tubes are used to track air currents in ventilation studies and to test respirators for proper fit in accordance with OSHA standards for irritant fume respirator fit test protocol. Each smoke tube consists of a pencil-sized sealed glass tube filled with pumice granules coated with approximately one gram per tube of "Stannic chloride, anhydrous, 8, UN 1827, II." The tubes are activated by breaking off the ends and pushing ambient air through with a small rubber bulb or motorized pump. Moisture in the air reacts with the stannic chloride and produces the smoke. The smoke tubes are sold in a box of ten tubes. A material described as "Stannic chloride, anhydrous, 8, UN 1827, IN" may be transported under the small quantity exception if it meets the quantity limits and packaging requirements in § 173.4, and is not forbidden under § 173.21. Based on the description of the "smoke tubes". may be transported under the small quantity exception provided the quantity of the Class 8 (corrosive) , it is our opinion that they material in the inner packaging (i.e., glass tube) is less than 30 grams (1 ounce) and all other provisions of § 173.4 are met. A package shipped in accordance with the small quantity exceptions in § 173.4 is not subject to any other requirements of the HMR, including labeling. The "smoke tubes" may also be shipped under the limited quantity exceptions for corrosive materials in § 173.154, which excepts such packages from the labeling requirements, unless offered or intended for transportation by aircraft. I hope this satisfies your inquiry. If we can be of further assistance, please contact us. Sincerely, Delmer F. Billings Chief, Standards Development Office of Hazardous Materials Standards 113.4 020092#

Page 2Engrum 5173.4 SENSIDYNE: Small Quantity xceptions 16333 BAY VISTA DRIVE, CLEARWATER, FLORIDA 33760 USA 02-0092 TEL: 800-451-9444, (727) 530-3602 (FL) FAX: (727) 539-0550 COMPANY: US DOT Ofeof Haz Mat Safety FROM: Ron Roberson FAX: 202-366-3012 DATE: March 25, 2002 ATIN: Delmer Billings. PAGES: 1 OF. - 1 SUBJECT: Ventilation Smoke Tube Shipping MESSAGE Dear Mr. Billings: My company sells smoke tubes that are used to track air currents in ventilation studies and also to test respirators for proper fit per the OSHA irritant fume respirator fit test protocol. Each smoke tube consists of a pencil-sized sealed glass tube filled with pumice of ten tubes, so ten tubes are the minimum number we would ship at one time. To use the granules coated with about one gram per tube of stannic chloride. They are sold in a box rubes, they are activated by breaking off the ends and pushing ambient air through with a small rubber bulb or motorized pump. Moisture in the air reacts with the stannic chloride We began shipping these tubes in the fall of 1983 believing that they met a small tubes was broken in transport. The broken tubes were activated by the sirrounding air quantity labeling exemption for stannic chloride. Within the first year or two a package of which caused them to produce smoke. The smoking package prompted a DOT official to instruct us to label the packages as hazardous material. We were told that because the Sine ta time (o, mid 15803) at be lin te smoke de in as it.:. 1827 and corrosive, and we have been paying the hazardous shipment fees on every shipment. azardous labeling. We share a common distributor who is questioning why our freigh A competitor of ours ships a similar stannic chloride smoke tube product without the harges include the hazardous fee and the competitor's do not. The competitor claims in form letter to customers that the tubes meet a small quantity labeling exemption under 49 CFR Part 173.4. 100 D#

Page 3Is the competitor's claim valid? Do the small. quantity descriptions in 173.4 apply to Sor abeing that does appry Can you est us if ten is thous another sin a uly try break. for our smoke tube packages? Your consideration of this matter is much appreciated, and we would like to receive a letter of interpretation for our files. Thank you for your kind cooperation. Sincerely, Ron Roberan Ron Roberson Corporate Industrial Hygienist & Technical Manager 200 7 ONE ENDORSNES 09906894LXE#