Mr. Steve Kranyec — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation 400 Seventh Street, S.W. Washington, D.C. 20590 Hazardous Materials Safety Pipeline and Adjoinistrati 2006 Mr. Steve Kranyec 2500 W. Main Street G16 Ref. No. 06-0027 League City, TX 77573 Dear Mr. Kranyec: This responds to your letter regarding the applicability of 180) to lighters that no longer contain fuel. the Hazardous Materials Regulations (HMR; 49 CFR Parts 171- you ask about requirements applicable to a lighter trat has Specifically, been purged of all fuel and a lighter containing residue amounts of fuel. and any inconvenience it may have caused. I apologize for the delay in responding It is ultimately the shipper's responsibility to ascertain whether a lighter is or is not subject to the HMR. lighter that contains no fuel (residual or otherwise) is not subject to the HMR. Most lighter manufacturers provide drain lighters to satisfy the requirements of the HMR. specific instructions to assist their customers to purge or the fuel reservoir in a gas-fueled lighter until it is empty Typically this process may consist of bleeding or purging (e.g., no longer contains liquefied gas or its vapors) or, wick and cotton fuel absorbing insert. for a "wick" style liquid-fueled design, removing both the lighter is purged or drained in accordance with the Generally, if a manufacturer's instructions and the lighter will no longer ignite, it is not subject to the HMR. 173.21 173.308 060027#

Page 2There is no certification required by the HMR to compliance with this requirement. I trust this satisfies your inquiry. Please contact us if we can be of further assistance. Sincerely, Hattie L. Mitchell Office Chief, of Hazardous Materials Standards Regulatory Review and Reinvention#

Page 304/03/1994 01:39 8323856314 RETURNKEY SYSTEMS PAGE 01 stevens $173.21 71/8/ Director Of Hazmat Standards Mr. Edward Mazzullo §173-308 PHH-10 400755SW US Department Of Transportation Lighters Washington,/DC 20590 2/8/05 06-0027 Dear Mr. Mazzullo, I would like to receive written clarification on DOT guidelines for shipping previously lighter must be treated as Hazmat. However, we have been told by members of DOT is present. However, nobody is certain of the definition of residue or how to determine and shipping agencies that lighters that do not light may be shipped as long as no residue certificate from a licensed purger must accompany any lighter that has been "drained" we have been told that a Can you please provide this information as soon as possible. If possible can you please email it to Kranyec@earthlink.net. Thank you for your attention to this matter. sincere Steve Kramyec 2500 W Main Street G16 League City, TX 77573#