Photographic Solutions, Inc. — Hazardous Materials Safety Interpretation

Page 1JAN 17 2006 Mr. David Stone Ref. No. 05-0304 Photographic Solutions, Inc. 7 Granston Way Buzzards Bay, MA 02532 Dear Mr. Stone: This is in response to your November 28, 2005 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Your company produces a liquid cleaning solution used by photographers. The cleaning solution consists of 100% purified methanol, and is packaged in 2 oz. (59 mL) plastic receptacles. Specifically, you ask if passengers may transport your company's product in checked or carry-on baggage aboard aircraft. A passenger may not transport a hazardous material in checked or carry-on baggage unless the material meets one of the exceptions in § 175.10. Methanol is listed in the Hazardous Materials Table (HMT; § 172.:01) as a Class 3 (Flammable liquid) material, and does not meet any of the exceptions specified in § 175.10. Therefore, your product is not permitted to be carried aboard an aircraft in a passenger's checked or carry-on baggage under the HMR. Sincerely, Chief, Standards Development Office of Hazardous Materials Standards 175.10 050304#

Page 225-0304 Dear USDOT, My company sells a liquid cleaner (called Eclipse) consisting of 100% purified methanol sold in 2 oz (59mL) plastic dropper bottle containers. It is used by professional and amatuer photographers in conjunction with our Sensor Swab Digital Imaging Chip Cleaner (a fancy Q-tip with no chemicals). A new, unopened bottle has a foil seal across the neck designed to be leak proof and a plastic screw cap to protect the seal. The cap must be turned approximately 2 full rotations to be removed. The bottle is a white HDPE plastic which is impervious to the chemical. As many of these photographers need to travel, and need to carry a cleaning kit with them to use while shooting, the question has come up as to whether or not such a container would be permissible to bring in carry-on or in checked luggage. It appears that some TSA checkpoints do not allow it and others look at the container and have no issue with it. I am hoping that DOT can clarify in writing its position so I can advise my customers accordingly. An MSDS and other product information can be found on our company web site at : http://www.photosol.com or please feel free to contact me at (508) 759 2322. Thank-you. David M. Stone, PHOTOGRAPHIC SOLUTIONS, INC. http://www.phetosol.com 7 Granston Way Buzzards Bay, MA 02532 (508) 759-2322 phone; E.S.T or E. D. T. use this i-name to contact me personally. It is spam proof!!! http://public.xdi.org/=David.Stone 11/28/2005#