Applied Biosystems — Hazardous Materials Safety Interpretation

Page 1U.S. Department of T-ansportation Washington, D.C. 20590 400 Seventh Street, S.W. Materials Safety Administration Pipeline and Hazardous FEB 28 2007 Ms. Connie Roxas Ref. No. 07-0020 Quality and Regulatory Compliance 850 Lincoln Centre Drive Applied Biosystems Foster City, CA • 94404-1128 Dear Ms. Roxas: This responds to your February 1, 2007 letter requesting clarification on proper shipping descriptions under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if two aqueous solutions of alcohol described in your letter are eligible for the exception in § 173.150(e). In accordance with § 173.150(e), aqueous solutions of alcohol containing 24% or less alcohol by volume and no other hazardous materials: (1) may be reclassed as a combustible liquid; and (2) are not subject to the requirements of the HMR if they contain no less than 50% water. According to your letter, both of your solutions of alcohol contain less than 24% alcchol by volume, no other hazardous materials, and also contain more than 50% water. Based on the information provided in your letter, it is the opinion of this Office that the two aqueous solutions of alcohol described in your letter are not subject to the requirements of the HMR. I hope this answers your inquiry. Sincerely, Office of hazardous Materials Standards 172.101 173.150 (e) 070020#

Page 2Boothe 3172.101 Applied $ 173.150 (e) Biosystems an Applera Corporation Business Shipping Name Foster City, CA 94404-1128 U.S.A 850 Lincoln Centre Drive 0-0020 T. 650 570 6667 F. 650 572 2743 February 1, 2007 www.appliedbiosystems.com Office of Hazardous Materials Standards 400 7th Street S.W. U.S. DOT/PHMSA (PHH-10) Washington, D.C. 20590-0001 Dear Sir or Madam: and marine transport. These solutions are used to ship slurry (16% w/v) of non-hazardous We are requesting a shipping clarification on two solutions that we manufacture and sell globally for air, ground chromatography media. We need to know if these two solutions are exempt under Section 173.150(e). Solution #1 - Flashpoint: 97 °F (Method ASTM D-93) (closed cup) Trade secret - non Material 0.71% w/V% hazardous chemical hazardous chemical Trade secret - non 0.39% w/v% Water Ethanol 22.00% Total 100.00% 76.90% V/N% V/V% Solution #2 - Flashpoint: 97 °F (Method ASTM D-93) (closed cup) Ethanol Material 22.0% Ratio Water 78.0% V/V% Total 100.00% v/v% All are shipped in non-bulk packaging. Sincerely, Corrie foxas Sr. Dangerous Goods Specialist Connie Roxas Quality and Regulatory Compliance#