McGowan Enterprises, Inc. — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department 1200 New Jersey Avenue, S.E Washington, D.C. 20590 Pipeline and Hazardous Materials Safety Administration JUN 27 2007 Mr. Jim Falls Ref. No.: 07-0097 12225 World Trade Drive, Suite F McGowan Enterprises, Inc. San Diego, CA 92128 Dear Mr. Falls: This is in response to your May 3, 2007 letter regarding the transportation of isopropanol under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if 70 percent isopropanol may be transported via air or highway transportation. In your letter you state that the 70 percent isopropanol is packaged in a combination packaging consisting of four one-gallon inner receptacles and in pre-saturated wipes. Provided your packaging meets the applicable requirements in Parts 173 and 178, the 70 percent IMT), the 70 percent isopropanol may not be offered for transportation in packages exceedin ontains 15.14 liters). As specified in Column 9A of the Hazardous Materials Table (§ 172.10 five liters net quantity when intended for passenger aircraft or passenger rail. Therefore, your combination packagings, as described, may not be transported by passenger aircraft or passenger rail. "Solids containing flammable liquids, n.o.s." Special provision 47 excepts from the HMR sealed Wipes containing isopropanol are most appropriately transported under the proper shipping name packets that contain less than 10 ml of a flammable liquid in Packing Group II or III when the liquid is completely absorbed onto a solid material. I hope this information is helpful. If you have further questions, please do not hesitate to contact this office. Sincerely, Hattie L. Mitchell Chief, Regulatory Review and Reinvention Office of Hazardous Materials Standards 172.101 070097#

Page 2• • Acute Care reness Pollack May 3, 2007 3172.101 Applicability Edward Mazullo, Director of OHMS USDOT-PHMSA 07-0097 East Building - 2d Floor 1200 New Jersey Avenue SE Washington, DC 20590 Re: Request for Letter of Interpretation Mr. Mazullo, Among many other products, we distribute 70% Sterile Isopropanol (sterile alcohol) in one 0% Distilled Water polyester wipers for use in compounding pharmacie allon containers, four gallon containers per case and pre-saturated 70% Sterile Isopropanol delivery (air transportation). I am not a security expert, yet it would appear that it would be safer The manufacturers of these products insist that they must be shipped to us via overnight overnight shipping is significantly more expensive versus ground transportation and these item: verall to transport this material on a truck, versus an airplane. As you may imagine, the cost of I would like to receive documentation that we can present to the manufacturers of these Your assistance is much appreciated. Please contact me directly with additional questions products and the freight companies in order to approve shipping of these materials on a truck Best Regards, a Falls, Via Fresdent a Contracts & Sales 12225 World Trade Drive - Suite F Acute Care Pharmaceuticals San Diego, CA 92128 Toll free: 888.909.7700 x6417 Cell: 858.243.6423 ifalls@acutecareonline.com#