Mountain Safety Research — Hazardous Materials Safety Interpretation

Page 120590 Real Program: dministratior OCT 16 2002 Mr. Joe Yelverton Mountain Safety Research Ref. No. 02-0219 3800 First Avenue South Seattle, WA 98134 Dear Mr. Yelverton: clarification of the Hazardous Materials Regulations (HMR; 49 CFR This is in response to your August 16, 2002 letter requesting product meets Parts 171-180). Specifically, you request confirmation that your the limited quantity provisions in $ 173.306 (a) (1). Commodity" and reclassed as "ORM-D" material. You also asked whether your product may be renamed "Consumer You describe your product as a 4 ounce capacity can containing liquefied petroleum gas (LPG). You also state that your product therefore, meets the definition of a "Consumer Commodity" as is intended to be sold to consumers for persónal consumption and, defined in § 171.8. Your understanding is correct: Your product consisting of a mixture of liquefied compressed gases in a container of not more limited quantity under § 173.306 (a) (1) of thé HMR and is, than four (4) fluid ounces capacity, meets the definition for a therefore, excepted from the specification packaging requirements and labeling requirements except when offered for transportation by air. Further, the provisions in § 173.306 specify that a limited quantity which conforms to § 173.306 (a) (1) and meets the Commodity" and reclassed as "ORM-D" material. definition of consumer commodity may be renamed "Consumer I hope this information is helpful. If you have further questions, please do not hesitate to contact this office. cerely, Delmer Billings Office of Hazardous Materials Chief, Standards Development Standards 173.30% 020219#

Page 2CASCADE Mountain Safety Research DESIGNS Webb $173.306 MSR Consum er Commodi thursday soun Joe Yelverton 82-02.19 Quality Assurance Division 3800 First Avenue South Direct 206-224-6194 Seattle, WA 98134 Joe.yelverton@cascadedesigns.com Fax 206-682-4184 www.msrcorp.com August 16, 2002 www.cascadedesigns.com RSPA Office of Hazardous Materials Standards (DHM-10) 400 Seventh Street, SW U.S. Department of Transportation Washington, DC 20590-0001 To whom it may concern: The contents of the can are: the can is intended to be sold for personal consumption per the definition of a Consumer Commodity. • Normal Butane = 5% • 2-Methyl Propane = 72% Propane = 22% In addition, I would like to request written interpretation of § 173.306(a) as it relates to the exceptior 11914), but in an 8 ounce can. Specifically, does a 4 ounce can (as previously described) qualify for an of "specification packaging." Currently, we have a DOT exemption for the same material (DOT-E exception, excluding the DOT exemption requirement? If you have any questions please do not hesitate to call me. Sincerely,#