Innovative Solutions & Technologies, L.L.C. — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department 400 Seventh St., S.W. research anc Washington, D.C. 20590 MAY 1 3 2003 Mr. Mike Lely Innovative Solutions & Technologies, L.L.C. Ref. No. 03-0078 2304 North 7t Avenue Suite C 4 Bozeman, MT 59715 Dear Mr. Lely: This responds to your March 5, 2003 letter requesting classification of your fire-starting product for outdoor emergency or recreational use under the Hazardous Materials Regulations (HMR; 49 CFR 171-180). Specifically, you are requesting assistance in classifying your new product under the HMR. According to your letter, you are developing a fire-starting product for outdoor emergency or recreational use. The product consists of a small plastic container about 1" in diameter and 3/4" tall, filled with 0.38 cubic inches of combustible material and an electronic igniter enclosed with a heat sealed lid. You currently sell a small portable hand crank generator that is used for powering small electronic devices. This generator is used to supply the power to ignite this fire starter also. The igniter in the fire starter has two 6" wire leads that are coiled up under the lid seal. The seal is first opened and the loads are unwound and attached to the generator cable alligator clips. Power is then supplied from the generator to the igniter and the combustible material burns at about 3000 degrees F for about 30 seconds. The combustible material is a mixture of 0.19 cubic inches of Orion road flare material and 0.19 cubic inches of Hodgdon pyrodex. The mixture is saturated with nitrocellulose lacquer and air- dried to solidify the mixture. The tungsten filament igniter is placed on the top of the mixture before air- drying and is adhered to the mixture after it dries. A polyethylene lid is then heat sealed to the top to enclose the product prior to retail packaging. Section 173.22 requires that the shipper properly class and describe the hazardous material in scordance with pants 172 prod 7ed of your letter and enlise dotend safety data fence, your fire- ccordance with starting product contains an explosive propellant with an igniter that may be a "new" explosive o pyrotechnic device under the HMR. New explosives must be examined by an approved person o he tests and criteria prescribed in §§ 173.52, 173.57 and 173.58. A list of agencies that are authorize gency and assigned a recommended shipping description, division and compatibility group based o to examine and test explosives is enclosed for your information. 113.22 030078#

Page 2In accordance with § 173.56, a person requesting approval of a new explosive must submit to the Associate Administrator a report of the examination and assignment of a recommended shipping description, division, and compatibility group. If the Associate Administrator finds the approval request meets the regulatory criteria, the new explosive will be approved in writing and assigned an EX number. I hope this answers your inquiry. Sincerely, am Hillo Delmer F. Billings Chief, Standards Development Office of Hazardous Materials Standards Enclosure#

Page 3Agencies Authorized to Examine and Test Explosives In accordance with the provisions of $ 173.56 (b) (1), the agencies Listed below are authorized to examine and test explosives in accordance with $§ 173.52, 173.57 and 173.58 and to recommend a addition, the agencies listed may assign tentative and compatibility group. classifications for samples of materials to authorize their Agencies Contact Person Address and Phone Explosives Bureau DI. W. S. Chang 407 Hartshorn Drive Short Hills, NJ 07078 Phone: 973-467-3237 Fax: 973-467-4648 Safety Consulting Engineers, Inc. Mr. C. James Dahn Schaumburg, IL 60173 2131 Hammond Drive Fax: 847-925-8120 Phone: 847-925-8100 services, Inc Safety Management Mr. Thaddeus C. Speed Suite 205 1847 West 9000 South West Jordan, UT 84088 Fax: 801-567-0457 Phone: 801-567-0456 Energetic Materials , Mr. Marvin Banks Center (EMRTC) Research and Testing email: EMRTC Marv@emrtc.nmt.edu Campus Station New Mexico Tech, Phone: Socorro, NM 505 835 5729 87801 Fax: 505 835 5630 E: \download\^explosives-agencies.wpd#

Page 4INNOVATIVE SOLUTIONS 406 522 9855 Ø3/11/03 12:24pm P. 002 406.522.9300 voice 406.522.9855 fax : www.insotech.biz To: Edward Mazzullo Boothe Director of the Office of Hazardous Materials Standards Routing # DHM-10 §173.22 Research and Special Programs Administration From: Mike Lely Shipper's Responsibility Innovative Solutions and Technologies 03-0028 RE: Hazardous Matcrial Classification for our product Datc: March 5, 2003 Dear Mr. Mazzullo, My company is developing a fire-starting product for outdoor emergency or recreational use. We arc currently in the late stages of production and seck your assistance in DOT hazardous material classification. Your direction of any procures that we need to follow will be greatly appreciated. Brief product description: inches of combustible material and an electronic igniter enclosed with a heat sealed lid. We currently sell The product consists of a small plastic container about I" Diameter and %" tall, filled with 38 cubic a small portable hand crank generator that is used for powering small electronic devices. This generator is used to supply the power to ignite this fire starter also. The igniter in the fire starter has two 6" wirc Icads the generator cable alligator clips. Power is then supplied from the generator to the igniter and the that are coiled up under the lid seal. The seal is first opened and the loads are unwound and attached to combustible material burns at about 3000 degrees If for about 30 seconds. The idea is to casily start a campfire in less than ideal situations. Combustible material details: The combustible matcrial is a mixture of.19 cubic inches of Orion road flare material and. 19 cubic inches of Hodgdon pyrodex. I included the MSDS for each of these materials. The mixture is saturated with nitrocellulose lacquer and air-dried to solidify the mixture. The tungsten filament igniter is placed is then heat sealed to the top to enclose the product prior to rotail packaging. on the top of the mixture before air-drying and is adhered to the mixture after it dries. A polyethylene lid ... - Plcase review this and let me know if you have any more questions or need more infornation. Your halp will be greatly appreciated. Sincerely, Mike Icly Manufacturers of the Side Winder Emergency cell phone charger#