Digital Innovations — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Avenue, SE Washington, D.C. 20590 SEP 1 2 2008 Mr. David Martin Digital Innovations 3436 N. Kennicott, Suite 200 Arlington Heights, IL 60004 Ref. No. 08-001 1 Dear Mr. Martin: This responds to your January 2,2008 request for clarification on the applicability of the Hazardous Materials Regulations (HMR: 49 CFR Parts 17 1 - 180) to your product.. Specifically, you ask if the exceptions in 9 175.10 apply to the transportation of your product, a C02 AirBlaster cleaning device, and its refill gas cartridges (cylinders). The answer is no. The exceptions in 05 175.1 O(a)(ll) and 175.10(a)(12) are limited to small gas cylinders used for self-inflating life jackets or mechanical limbs under the conditions specified. I hope this answers your inquiry. Sincerely, Susan Gorsky Acting Chief, Standards Development Office of Hazardous Materials Standards#

Page 2?30o+-hc Page 1 of 2 3 115- I0 Drakeford, Carolyn <PHMSA> m < "-- -<* "" +- --- "- - . " We - From: INFOCNTR <PHMSA> Sent: Wednesday, January 02,2008 1 :00 PM To: Drakeford, Carolyn <PHMSA> Subject: FW: Attachments: Co2 MSDS.doc Request for letter of interp. From: David Martin [mailto:dave@comclark.com] Sent: Tuesday, January 01, 2008 9:29 AM To: TSA-ContadCenter@dhs.gov Cc: INFOCNTR <PHMSA> Subject: Dear TSA Customer Service and Hazardous Materials Information Center: 49 CFR - CHAPTER I - PART 175.10 (a)( 1 1) indicates that a passenger may carry a Life Jacket fitted with no more than two small gas cartridges (containing no hazardous material other than a Div. 2.2 gas) for inflation purposes plus no more than two spare cartridges. Likewise PART 175.10 (a)(12) provides that a passenger could wear a mechanical limb operated by "Small compressed gas cylinders of Division 2.2" and carry "spare cylinders of a similar size for the same purpose in sufficient quantities to ensure an adequate supply for the duration of the journey." Note that in this case they are not limited to no more that two such cartridges. On your webpage ~t~1/1.4y~~w~~go~vltra~.t:k~~s!cu.st~.1ne_r1:Ind.c.x~sh~~ you say in part: Our common-sense approach borrows and adapts the best ideas from business and industry. The goal is not just to make people feel safe, but to ensure that they really are safe. In keeping with that concept, I request a Letter of Interpretation regarding my transporting the end user product: Digital Innovations "AirDR@ AirBlaster C02TM", a description of which is found here: I also wish to transport the refills for this device, which come in blister packs containing four such small gas cartridges, and which can be seen at the URL below, and thus I also request a Letter of Interpretation regarding the transportation of this product: The Material Safety Data Sheet for these cartridges from the manufacturer of this device is attached to this email.#

Page 3Page 2 of 2 The Hazard name is "Carbon dioxide" ; Hazard is 2.2; Class or Division is UN1013. Since you are allowed to carry a greater amount of these cylinders than two if they are accompanied by a mechanical limb ... you can carry "...sufficient quantities to ensure an adequate supply for the duration of the journey.", it seems reasonable that carrying one or two of these four packs of refills for the Digital Innovations cleaning device would ensure the same level of safety. Since I travel frequently to the Philippines, and need these cylinders for use there, where they are not available for purchase, I request this Letter of Interpretation that it is permissible to carry more than two of such cylinders in my checked or carryon baggage, or at the least a written clarification that I could present to baggage screeners agreeing that it permissible for me to carry the two refill cartridges without the accompanying life jacket. Certainly a reasonable person or agency would not be able to say that passengers would be any less safe with these cylinders in baggage without the accompanying life jackets or mechanical limbs than they would be with such devices accompanying the cylinders. It is obvious to me that whoever wrote these rules simply did not foresee other uses for such cylinders other than life jackets or mechanical limbs, but such legitimate other usages do now exist. It would seem to me to be unreasonable to assign any greater risk to such cartridges without a life jacket or mechanical limb accompanying them than would be present if there were a life jacket or mechanical limb accompanying them. If your interpretation of the existing regulations does not support my contention that it is safe and permissible to carry such cylinders in checked or carryon baggage on passenger flights, then I request an exception from the regulations to be able to do so. Thank you for your help. -- Best Regards, Dave Martin#

Page 4MATERIAL = F E ~ DATA SHEET OEaE-RfL WSC l h c ~ d % ~ l p f q l a r & P W D X T TTESCRIPnON, CMaC&u,4, mWms gaz ~4~ ~74gk; az151; txh:#

Page 5MATERIAL SAFETY DATA SHEET April 1.2002 PHODUCT NAME CARBON DIOXIDE, GAS Page 2 of 4 SECTION 4 - FIRST AID MEASURES INHALATION: Remove afiocted person to fresh air: provide oxygen if trathing is difficult; if affected person is not breathing, administer CPR and seck emergency medical attention. SKIN: Wash affaced area with soap and water, it irritation persists, seek medical attention. allenson. EYES. Remove contact lenses. Flush ayes with cliar turing water for 15 minutes while holding cyclide open if iritation persists, seek medica! INGESTION: Not expected under normal conditions due to gaseous state. SECTION 5 - FIRE FIGHTING MEASURES FLASH POINT (METHOD USED) FLAMMABLE LIMITS Non - Mammable AUTOIGNITION TEMPERATURE: LEL: Not applicable UEL: Not appicable Not determined NFPA CLASS: None GENERAL HAZARDS: Product is no, flaminable or combusible: Products of carcustion include compounds of carton, hydrogen and oxygen, including curbon monoxide. EXTINGUISHING MEDIA Caster disside, water, water fog dry chemical, chamical fran FIRE FIGHTING PROCEDURES Sell-contained respiratory equpment cool continets to prevent pressure buildup and possible explosion when exposed to extreme heat UNUSUAL FIRE AND EXPLOSION HAZARDS heat saurois. Closed containers can axplode due 1o buddup of pressure when exposed to extreme heat. Contents under pressure. Do not use or store near HAZARDOUS COMBUSTION PRODUCTS Smoke, fumes, oxides, of carton; SECTION 6 - ENVIRONMENTAL RELEASE MEASURES STEPS TO BE TAKEN IN CASE MATERIAL IS RELEASED OR SPILLED: Evacuate and ventilate area SECTION 7- HANDLING AND STORAGE protect from astrame imperatures, Neap away from sources of heat. Do not puncture container. Do not attempt to refll container. Maintain PRECAUTIONS TO BE TAKEN IN HANDLING AND STORAGE: Keep container cased when nat in use; protect containers from abuse wall ventilated work arees to minimize exposura when harding this material. SECTION 8 - EXPOSURE CONTROLS/ PERSONAL PROTECTION ENGINFFRING CONTROLS The use of local exhaust vonlilation is nequired to control emissions near the source. Provide mechanical ventiation of conned apaces. Ser Secion 2 for Companart Exposure Guidelnes. PERSONAL PROTECTION: concentrations, if TiNk exconds fris, NICH approved respirator must be wom. Refer to 29 CFR 1910.134 or European Standard EN 149 for RESPIRATORY PROTECTION (SPECIFY TYPE). None required while threshold limits (Section 2) are kept below maximum allowable complate rogulations PROTECTIVE GLOVES: Recommended for goneral protection EYE PROTECTION Protective eyeglass or chemical safety goggles, Acferto 29 CFR 1910,133 or European Standard EN165 WORK I HYGIENIC PRACTICES: Practice sale workplace habits. Minimize body contact with this, as wet as all chemicals in general OTHER PROTECTIVE CLOTHING OR EQUIPMENT Safely eyebal) nearby#

Page 6MATERIAL SAFETY DATA SHEET PRODUCT NAME: CARBON DIOXIDE, GAS Parl 1: 2002 Pape 3 of 4 VAPOR PRESSURE: (MV Hg) SECTION 9- PHYSICAL AND CHEMICAL PROPERTIES SPECIFIC GRAVITY WATER - 11 5.50 рва ü 20° C VAPOR DENSITY ¡AIR = 1) 1.53 SOLUBILITY IN WATER Not availeble: EVAPORATION RATE (WATER = T; FREEZING POINT ph. -89.8° Г (-55.6 C) BOILING POINT Not availabla APPEARANCE AND ODOR Colorices, odorless gas VISCOSITY -1093, F 1-78.6* C) PHYSICAL STATE Gas Gas VOLATILE ORGANIC COMPOUNDS (Total VOCs) SECTION 10 - STABILITY AND REACTIVITY None STABILITY UNSTABLE STABLE CONITIONS TO AVOID: Extreme temperadures, open Rames, sparks INCOMPATINILITY (MATERIALS TO AVOID;: Strong oxidizers, shong acide HAZARDOUS DECOMPOSITION OR BYPRODUCTS: Decomposition will nat cocur it hansled and stored properly, In case of a firo, axides of HAZARDOUS POLYMERIZATION: cabinItrocantons, fumes, and smoke may be produced WILL NOT OCCUR: 3KK MAY CCCUR: CONDITIONS TO AVOID: None SECTION 11- TOXICOLOGICAL INFORMATION Hazardaus Ingredients CAS F (Specify, Species and Rouse) LD50 af ingredient LCSO af Isgrodient Information not found Information not found (Spocify Specien) Carbon dioxido 100 124-38-9 SECTION 12 - ECOLOG/CAL INFORMATION chemical composition of this product it is assumed that the mixture can be treated in an acrimatized biological waste trestment plant system in No data are avalable on the adverse effects of this materil on the environmer. Neither COD nor BOO data are avalable, Based on the limited quantities. However, such treatment shauk be evakiated and epproved for each specific biological systom. None of the ingredients in this mixture are classified as a twine Pollutant. SECTION 13 - DISPOSAL CONSIDERATIONS chemicals Do not flush to spritary sewer or waterway. SECTION 14 - TRANSPORT INFORMATION PROPER SHIPPING NAME: Carbon dioxide DOT HAZARD CLASS /Pox Group: 22 REFERENCE: 49 CFR 173.115, 306, 307 JATA HAZARD CLASS / Pack Grous: 22 UN /NA IDENTIFICATION NUMBER: UN 1013 RIDIADR Dangerous Goods Code: 22 SADG HAZARD CLASS. 2.2 HAZARD SYMBOLS: None LABEL: NONFLAMMABLE GAS UN TOG Cass/ Pack Grous: 22 Note: Transportstion infornation provided an for reference only. Clent is urged to consult CFR 49 para 100 - 177. IMDG, INTA, EC, United pockaging materials and methods of shipping Nations TDG, and WUHMIS (Canada) TDG information manuals for detailed regulations and exceptions covering specific container sizes.#

Page 7PRODUCT NAME MATERIAL SAFETY DATA SHEET April 1.2032 CARBON DIOXIDE GAS Page 4 of 4 SECTION 15 - REGULATORY INFORMATION TSCA (Toxic Substance Control Act) Components of this product are listed on the TSCA Inventory. 311/312 Hazard Categories SARA TITLE I (Supirfund Amendments and Reauthorization Act) Sudden release of pressur 313 Raponable Ingredients: Nore CERCLA (Comprehensive Response Comperation and Liability Act) None CeR (Canadian Controlled Products Regulations) intormation resuired by the Controlled Predicts Reguialions. This product has been dlassified in accordance with the hazard cilena of the Controlce Products Regusations and me MSDS contains altite IDL (Canadian Ingredient Disclosure List) Components of this product identified by CAS sumber and sted on the Canadian Ingredient Disidosure List are shown in Section 2. DSL / NDSL (Canadian Domestic Substances List / Non-Domestic Substances List) document. Only ingrediants dassified as "hazardous" are listes in Section 2 unloss othorvise indicated Corponents of this product identified by CAS numper are sled on Ise DSL or NOSL and may or may not be asled in Seclion 2 of thia EINECS (European Inventory of Existing Connercial Chemical Substances) Corponents of this product identified by CAS numbers are on the European inventory of Existing Commercial Chemical Substances. EC Risk Phrases R20 Hamful by inhalation. EC Safety Phrases S38 In case of insufficient ventilation, wear suitable respicatory SECTION 16 - OTHER INFORMATION No specific notes. HMIS HAZARD RATINGS HEALTH FLAIMABILITY REACTIVITY : 0= INSIGNIFCANT • 1 - SLIGHT 9 - HIGH 2 = MODEROITE 4 = EXTREME PERSONAL PROTECTIVE EQUIPMENT B Safely Grancs, Govea REVISION SUMMARY: ascions: This MSDS has been revaed in the following No revisions available MSDS Preparad by: Chem Tel Ins Tismpa, Morida USA 33602 1305 N. Florida Ave The information contalmed hemin/s believe to he accurate tut is not warranted to bo so bats and caleulations are bused on information fumished by the 1800; 256-3024 Outside US/ (815|248-0573 manufacture of the product ant mandicturers of use coirponents of the product. Unry am adviand to confion in advance of need that information is cursint, onleable and sullen ta the documstances of use. Vendor assumes no meannihilis far blury le vendoe or third ersons broximatel caused by the matmal f of this material even if reusemble safety procedures are tollbaed. Any cuestions regarding this produet should be directed to the manufacturer of the produst as reasonable safety procedures are het adhered to 25 stipulated in the dola shoel, Furtherinera, vencor assumes no responsibility for injury caped by abnamal use describod in Sectinn t.#

Page 8Disc care and disc repair solutions, gaming care and maintenance, security solutions, PSP ... Page 1 of 1 Model Number: 30103 AirDRB AirBlaster COZTM Blast away dust from cameras, keyboards, computers, A N components, and office equipment with pinpoint accuracy. SkipDRTM Advanced Disc Repair System $29.99 Revive damaged music CDs, movie DVDs, game, photo and data discs in about a minute. ADD TO CART Pure, oil-free, anti-static C02 gas delivers higher- velocity airflow than canned air Compact size housing with easy-to- replace 16-gram air cartridges Replacement cartridges available (four-pack, model 301 04 00) $1 2.99 AQD TO CART SkipDRTM AutoMax@ Motorized Disc Repair System $39.99 Automatically fix scratched ADD TO discs: Music CDs, movie CART DVDs, game, photo and data discs CleanDR@ Motorized Disc Cleaner $1 4.99 Ensure non-stop disc play by ADD TO removing disc surface grime CART automatically .e CleanDRcP3 Screen Cleaner Microfiber Wand $7.99 Get the best picture possible from small screens such as ADD TO CART laptops and smaller monitors. CleanDRcP3 Optical Lens Reduce skips and optimize CD, DVD and game system $1 1.99 ADD TO CART & CleanDR@ Screen Cleaner Kit $14.99 Clean all types of screens and electronics safely and easily for ADD TO ,-ART optimal viewing. Home I About Us I News 1 Retailers 1 Support ( Register 1 Products 1 Privacy Policy Disc Repair I Disc Care I Home Theater I Office I Electronics Care 1 Gaming#

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