Abbott — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department 1200 New Jersey Avenue, SE Washington, D.C. 20590 Pipeline and Hazardous Materials Safety Administration ПП 12 2007 Ms. Alicia Gaines Ref. No.: 07-0091 Abbott Manager, Global Dangerous Goods Program Dept. 0539, Bldg. AP52-S 200 Abbott Park Road Abbott Park, Illinois 60064-6212 Dear Ms. Gaines: This is in response to your letter dated May 4, 2007 requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) requirements applicable to sample aerosol products classed as Division 2.2 with no subsidiary hazard carried on board an aircraft in checked baggage for business purposes. Specifically, you ask if an employee carrying company products may utilize the exception provided in § 175.10(a)(1)(ii) for these products provided the quantity limitations in § 175.10(a)(1)(111) are met. The answer is yes. As provided by § 175.10(a)(1)(ii), aerosols of Division 2.2, with no subsidiary hazard meeting the quantity limits of paragraph (a)(1)(iii) may be carried in suitable means to prevent inadvertent release. Flammable aerosols that are not medicinal checked baggage only. Release devices on aerosols must be protected by a cap or other or toilet articles for personal use are not permitted in checked or carry-on baggage. I hope this information is helpful. Sincerely, LASSI Chief, Standards Development Office of Hazardous Materials Standards 175.10(al1) 070091#

Page 2neary $175.10 (a)1) Air ABBOTT 07-0091 Alicia Gaines Manager. Global Dangerous Goods Program Dept. 0539, Bldg. AP52-S ›bott Park. Illinois 60064-62 obal Environmental. Health, Safety & Ene Facsimile: (847) 937-9679 Office: (847) 937-5650 Alicia. Gaines@abbott.com May 4, 2007 Mr. Edward T. Mazzullo U.S. DOT/PHMSA (PHH-10) Director, Office of Hazardous Materials Standards 1200 New Jersey Avenue, SE East Building, 2nd Floor Washington, DC 20590 Re: Request for interpretation concerning carrying aerosols classified as Division 2.2 non flammable gas per 175.10(a)(1). Dear Mr. Mazzullo In reviewing the regulations below, I have a question regarding applicability pertaining to 49 CFR 175.10 (a) (1). 49 CFR 175.10 (a) (1) (ii) Other aerosols in Div. 2.2 (nonflammable gas) with no subsidiary risk carried in checked baggage only. Release devices on aerosols devices on aerosols must be protected by a cap or other suitable means to prevent inadvertent release; (iii) The aggregate quantity of these hazardous materials carried by each person may not exceed 2 kg (70 ounces) by mass or 2 L (68 must be protected by a cap or other suitable means to prevent inadvertent release: and fluid ounces) by volume and the capacity of each container may not exceed 0.5 kg (18 ounces) by mass or 500 ml (17 fluid ounces) by volume. Utilizing 49 CFR 175.10 (a)(1)(ii) can an employee who is employed by a company carry final products, samples of products for users era busines aroses that are lasi ed as agrao pren quan in a 1) wita using risk in their Sincerely Alicatures Alicia Gaines Manager, Global Dangerous Goods Program a Abbott A Promise for Life#