Allegro MicroSystems, Inc — Hazardous Materials Safety Interpretation

Page 1f Transportatio .S. Departmer 1200 New Jersey Avenue, SE Washington, D.C. 20590 Materials Safety ipeline and Hazardou Administration OCT 29 2007 Mr. Donald W. Alger Ref. No.: 07-0172 115 Northeast Cutoff, Box 15036 Allegro MicroSystems, Inc. Worcester, MA 01615 Dear Mr. Alger: exception prescribed in § 173.6 of the Hazardous Materials Regulations (HMR; 49 CFR Parts This responds to your letter dated August 30, regarding clarification of the materials of trade 171-180), as it applies to the transport of "UN1219, Isopropyl alcohol, 3, PG II" between several of your company's chemical plants. You state that your company is located in Worcester, Massachusetts and a "sister" plant is located in Manchester, New Hampshire. From time to time, you get a request from the Manchester plant for some Isopropyl alcohol. You ask whether the materials of trade (MOTs) exception in § 173.6 applies to the transport of the Isopropyl alcohol (or other chemicals) in your company-owned and-operated vehicles from your Worcester plant to your Manchester plant. A material of trade is defined in § 171.8, as a hazardous material, other than a hazardous waste, that is carried on a motor vehicle: (1) For the purpose of protecting the health and safety of the motor vehicle operator or passengers; (2) For the purpose of supporting the operation or maintenance of a motor vehicle (including its auxiliary equipment); or (3) By a private motor carrier (including vehicles operated by a rail carrier) in direct support of a principal business that is other than transportation by motor vehicle. Based on your scenario, it appears that your company meets the third criteria. Provided that Ill conditions in § 173.6 are met, your company may take advantage of the MOTs exceptior Tazardous materials that are transported in accordance with $ 173.6 are not subiect to an In accordance with § 173.6, the Isopropyl alcohol you transport between your facilities must be in a packaging with a gross mass or capacity no greater than 66 pounds or 8 gallons. You 173.6 070172 171.8#

Page 2may transport more than one package in the same vehicle provided that the aggregate gross weight of the MOTs on the vehicle does not exceed 440 pounds. Packages must be leak tight movement, and protected against damage. Each material must be packaged in the for liquids and gases, sift-proof for solids, and be securely closed, secured against shifting or manufacturer's original packaging, or a packaging of equal or greater strength and integrity. I hope this satisfies your inquiry. If we can be of further assistance, please contact us Sincerely, Chief, Standards Development Office of Hazardous Materials Standards#

Page 3Request for Determination ingrum Page 1 of 1 3172. 700 Drakeford, Carolyn <PHMSA> $ 173.6 From: INFOCNTR <PHMSA> Training Sent: Thursday, August 30, 2007 11:14 AM To: Drakeford, Carolyn < PHMSA> 07-0173 Subject: FW: Request for Determination Wants a written letter of Interp. From: Alger, Donald W [mailto:DAlger@ALLEGROMICRO.com] To: INFOCNTR <PHMSA> Sent: Thursday, August 30, 2007 10:11 AM Cc: Mahoney, Denis C; Moquin, William T Subject: Request for Determination Completed via phone by RB @ 11:10 am on 8/30 Hello, I am contacting you for a Request for Determination. We are located in Worcester, MA and have a sister plant in few. From time to time we get a request from them for some isopropyl alcohol (IPA). My question is whether Manchester, NH. We use a reasonable amount of chemicals in our process, but the Manchester plant uses very transport of this IPA (or other chemicals) from here to Manchester falls under the Materials of Trade rule. Can our requirements for these employees? Regarding quantity limits, do we follow those specified in the "What Are employees legally transport IPA or other chemicals to the Manchester plant, or vice versa? Are there any special Materials of Trade" booklet?. For IPA, it specifies a limit of 8 gallons in each package. Does that mean you can transport 16 gallons as long as there are no ore that 8 in each package? Thank you. Donald W. Alger Senior Environmental Engineer Allegro MicroSystems, Inc. 115 Northeast Cutoff, Box 15036 Worcester, MA 01615 fax (508) 856-7435 phone (508) 854-5560 dalger@allegromicro.com 8/31/2007#