Prometheus International, Inc. — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department 400 Seventh Street, S.W Washington, D.C. 20590 Hazardous Materials Safety Pipeline and Administration OCT 18 2006 Mr. Keith K. Park President Ref. No. 06-0209 Prometheus International, 6231 Bandini Boulevard Inc. Commerce, CA 90040-3113 Dear Mr. Park: This responds to your letter regarding the applicability of 180) the Hazardous Materials Regulations (HMR; 49 CFR Parts 171- provided in your letter to a new model, refillable butane gas lighter. a drawing of a "traveling" lighter attached to each other and fueled, work as a standard gas design that contains three separate components that, when lighter. You ask whether the top and bottom components may without the fuel reservoir. be carried aboard an aircraft separated from each other and is yes. A lighter that contains no fuel or residue thereof and does not contain any other hazardous material is not subject to the HMR. It appears that your lighter design would meet this requirement. The Transportation Security Administration (TSA), the agency responsible for security in all modes of transportation, including civil aviation, has the authority to restrict passengers from carrying materials perceived as materials that they believe securitys heat she before stical miss in ate the materials are not classified as hazardous under the 171.8 060209 173.308#

Page 2HMR. To be sure that your separated lighter components will not be confiscated, you should contact TSA concerning your device. we can be of further assistance. I trust this satisfies your inquiry. Please contact us if Sincerely, Holly z. Mada Hattie I. Mitchell Chief Regulatory Review and Reinvention Office of Hazardous Materials Standards#

Page 3Stevens $ 173.308 Prometheus § 171. 8 Keith K. Park President Keith. Park@prometheuskkp.com www.prometheuskkp.com (16 September 11, 2006 AUG HAZM! 12 Mr. Kenny Herzog 2000 US Department of Transportation 0- 400 7th Street SW Room 8100-B Washington, DC 20590-0001 сл Dear Mr. Herzog, I am writing you to ask for a clarification on our new butane gas, refillable lighter, Prometheus Traveler. removed from the upper and lower cases of the lighter. Once the gas tank is removed, it is impossible for the The unique feature of the Prometheus Traveler lighter is that the butane gas tank of the lighter can be easily upper and lower cases to generate flame on their own. In other words, once the gas tank is removed, the upper and lower cases are not a lighter any more, and cannot function as a lighter. Please see the enclosed We would like to know whether a traveler can carry the upper and lower cases of the Prometheus Traveler upper and lower cases of the Prometheus Traveler lighter into an airplane will be like carrying two metal lighter (not assembled, but separately) into an airplane (of course, without their gas tank). Carrying the If you need any further information from us, please let us know. Your prompt assistance will be greatly appreciated. Best regards, Keeps Keith K. Park Prometheus International, Inc. 6231 Bandini Boulevard, Commerce, California 90040-3113, U.S.A.#