Central States Fireworks — Hazardous Materials Safety Interpretation

Page 1U.S. Department 200 New Jersey Ave. S Pipeline and Hazardous of Transportation ПСТ 16 2007 Vashington. DC 2059 Administration Materials Safety Mr. Alex Weise Ref. No. 07-0164 Central States Fireworks 18034 Kincaid St. Athens, IL 62613 Dear Mr. Weise: by highway under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). This is in response to your August 29, 2007 email regarding the transportation of explosives In your letter, you ask whether a truck bed lining manufactured from a spray-on polyurethane 1.4G (explosive) materials as specified in § 177.835(f) of the HMR. coating meets the requirements for a lining of a motor vehicle transporting Division 1.3G or Paragraph (f) of § 177.835 specifies the requirements for the lining of a motor vehicle this Office that provided it consists of either non-metallic material or non-ferrous materials transporting Division 1.1, 1.2, or 1.3 (explosive) materials by highway. It is the opinion of and complies with the remainder of the requirements in § 177.835, a truck bed lining manufactured from a spray-on polyurethane is an acceptable lining for a motor vehicle transporting Division 1.1, 1.2, or 1.3 (explosive) materials by highway. There is no similar provision for the lining of a motor vehicle transporting Division 1.4 (explosive) materials by I hope this information is helpful. Sincerely. Chief, Standards Development Office of Hazardous Materials Standards 177.835 (f) 070164#

Page 2Foster Page 1 of 1 $177.835 (f) Drakeford, Carolyn <PHMSA> Explosives by Highway 07-0164 From: INFOCNTR < PHMSA> Sent: Wednesday, August 29, 2007 1:02 PM To: Drakeford, Carolyn < PHMSA> Subject: FW: letter of interpretation regarding 49 CFR 177.835 paragraph (f) Carolyn, Could you process this as a formal request for interpretation? Thanks a million! Erin From: Weise, Alexander Walter [mailto:aweise@uiuc.edu To: INFOCNTR <PHMSA> Sent: Tuesday, August 28, 2007 5:02 PM Subject: letter of interpretation regarding 49 CFR 177.835 paragraph (f) Hello, I have a question regarding Hauling of 1.3g and 1.4g fireworks As per 49 CFR 177.835 paragraph (f) it states the following: (f) Class 1 (explosive) materials vehicles floors tight and lined. Motor vehicles transporting Division 1.1, 1.2, or 1.3 (explosive) materials shall have tight floors; shall have that portion of the interior in contact with the load lined with either non-metallic material or non-ferrous metals, except that the lining is not required for truck load shipments loaded by the of such nature that they are not liable to leakage of dust, powder, or vapor which might become the cause of an explosion. Departments of the Army, Navy or Air Force of the United States Government provided the Class 1 (explosive) materials are The interior of the cargo space must be in good condition so that there will not be any likelihood of containers being damaged by exposed bolts, nuts, broken side panels or floor boards, or any similar projections. So my question is... Will a bed liner material "brand names of scorpion bed liner or rhino liner as examples for truck bed liners" meet spray-on polyurethane coating and is a non slip surface when dry see info at http://www.scorpioncoatings.com/ the requirement "lined with either non-metallic material or non-ferrous metals" by definition. This product is a Thanks for your time in this matter Alex Weise on behalf of: Larry and Vivian Lefferts 18034 Kincaid st. C/O Central States Fireworks Athens IL 62613 Thank you for your time In this matter. 217-265-8225 8/29/2007#