Associated Spring Raymond — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department Washington, D.C. 20590 400 Seventh Street, S.W. Pipeline and Administration Hazardous Materials Safety JUL 7 2006 Mr. Thomas J. Fischer Associated Spring Raymond Ref. No. 06-0142 1705 Indian Wood Circle, Suite 210 Maumee, OH 43537 Dear Mr. Fischer: This is in response to your letter requesting clarification of the applicability of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) to nitrogen-charged gas regulated under the HMR, although you state: "Shipping via air will still require proper springs. You ask for confirmation of your understanding that the gas springs are not compliant with IATA standards for air transportation." coding (UN1066), labeling (non-flammable) and the proper hazardous paperwork to be devices are not subject to the HMR provided they meet the criteria specified in Accumulators intended to function as gas springs or other impact or energy-absorbing § 173.306(f)(4). Such gas springs also are not subject to the International Civil Aviation's (ICAO) Technical Instructions provided they meet the Technical Instruction's criteria in Special Provision A114. The HMR authorizes the use of the ICAO Technical Instructions with certain exceptions as an alternative to the HMR, but does not authorize the use of the IATA Dangerous Goods Regulations. For questions regarding the use of the IATA Dangerous Goods Regulations, we suggest you contact the organization at 514/390-6770. I hope this information is helpful. Please contact this office should you have additional questions. Sincerely, Hattie L. Mitchell Office of Hazardous Materials Standards Chief, Regulatory Review and Reinvention 173.306 f) 4) 060142#

Page 2Jun-22-2006 02:49pm From-ASSOCIATED SPRING RAYMOND 4198910419 T-520 P. 001/001 F-136 Associated Spring Associated Spring - Raymond Raymond BARNES 1705 Indian Wood Circle GROUP INC MIntyre Suite 210 3173.306 Phone: 419-891-9292 Maumee, OH 43537 Fax: 419-891-0419 Compressed Gas June 22, 2006 06-0142 Office of Hazardous Material Standards Was Dingon, Dacof Transportation To Whom It May Concer: Recently I had a conversation with Kurt from the Hazardous Materials Standards Office to clarify detail related to Blow I have listed the specific DOT detail for which we are altempting to receive the interpretation against. 173.306(D(4) absorbing devices arc not subject to the requirements of this subchapter provided each: (4) Accumulators intended to function as shock absorbers, struts, gas springs, pneumatic springs or other impact or energy- 173.306(D(4)(i) capacity expressed in L and charge pressure expressed in bars does not exceed 80 (for example, 0.5 L gas space and 160 bar (i) Has a gas space capacity not excecding 1.6 L and a charge pressure not exceeding 280 bar, where the product of the 173.306(D)(4)(ii) charge pressure); and 5 times the charge pressure for products greater than 0.5 L gas space capacity; (ii) Has a minimum burst pressure oi 4 times the charge pressure at 20°C for products not excecding O.5 L gas space capacity 173.306(f)(4)(iii) degradable seal or other pressure relief device, such that the article will not fragment and that the article does not rocket; and (iii) Design type has been subjected to a fire test demonstrating that the article relieves its pressure by means of a fire 173.306(f)(4)(iv) burst strength, burst mode and performance in a fire situation as specified in paragraphs (f(4)(i) through (f)(4)(iil) of this (iv) Accumulators must be manufactured under a written quality assurance program which monitors parameters controlling section. A copy of the quality assurance program must be maintained at each facility at which the accumulators are 173.306(D(5) manufactured. transported subject to the approval of the Associate Administrator. (5) Accumulators not conforming to the provisions of paragraphs (D)(1) through (f) (4) of this scction, may only be that all product can ship via ground transportation with no special tags such as Non-Flammable or Hazardous Material. Our current product meets and has been tested against all items as they have been identified. Therefore we understand Shipping via air will still require proper coding (UN1066), labeling (Non-Flammable) and the proper hazardous papcrwork to be compliant with TATA standards for air transportation. Your prompt response on this matter is appreciated Please conract me with any questions the DOT might have. Thomas J. Fischer Sinccrely Product /Quality Engincer Associated Spring Raymond#