Photosol, Inc. dba Photographic Solutions — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation 1200 New Jersey Avenue, SE Washington, D.C. 20590 Materials Safety Pipeline and Hazardous Administration APR 1 5 2016 Mr. David M. Stone President Photosol, Inc. dba Photographic Solutions 430-G Ansin Blvd. Hallandale, FL 33009 Ref No.: 15-0153 Dear Mr. Stone: This letter is in response to your July 22, 2015 email requesting clarification to the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to a product your company produces and markets. The specific product in question is a "wash n dry" style packet containing an absorbent synthetic cloth with approximately 3 drops (3mL) each of methanol, a Class 3 (flammable) liquid. You state there is no free liquid present as it is completely absorbed by the material and fully sealed within the packet. Under the HMR, your company's product would be appropriately described as "UN3175, Solids containing flammable liquid, n.o.s., 4.1, PG II." However, as specified in § 172.102(c)(1), Special provision 47, small inner packagings consisting of sealed packets containing less than 10 mL of a Class 3 (flammable) liquid in Packing Group II or III, and absorbed into a solid material are not subject to the requirements of the HMR provided there is no free liquid in the packet. I hope this information is helpful. Please contact us if we can be of further assistance. Sincerely, Tatern Tota T. Glenn Foster Chief, Regulatory Review and Reinvention Branch Standards and Rulemaking Division 1#

Page 2Stevens 173.4 Goodall, Shante CTR (PHMSA) Smael quantities From: Geller, Shelby CTR (PHMSA) 15-0153 Sent: Wednesday, July 22, 2015 2:09 PM To: Hazmat Interps Subject: FW: formal Letter of Interpretation request Dear Shante and Alice, Please see the request for a formal letter of interpretation below. I spoke with Mr. Stone about his request. Thanks, Shelby From: david4w@gmail.com [mailto: david4w@gmail.com] On Behalf Of David M. Stone To: INFOCNTR (PHMSA) Sent: Wednesday, July 22, 2015 1:07 PM Subject: formal Letter of Interpretation request formal Letter of Interpretation request (LOI) 22 July 2015 Dear USDOT, My company produces and sells a "wash n dry" style packet containing an absorbent synthetic cloth with approximately 3 drops (3ml) each of methanol. There is no loose liquid as it is all absorbed by the material and fully sealed within the packet. Around 1990, I received an LOI from the USDOT which stated that due to the limited amount of Our dand the fact on at se ligaid was lapsent these tians presented so hazard when ed tod or transportation. Now that 2J We have been a certified hazmat shipper for over 30 years, with no incidents what-so-ever, and are current with all of our certifications. I see nothing in CFR 49 (part 100-177) to indicate a change that might render the original LOI invalid. The original LOI would have been addressed to us in Massachusetts as follows : Photographic Solutions, Inc. P.O.Box 135 Onset, MA 02558 or 7 Granston Way or 260 Main Street Buzzards Bay, MA 02532 Please note our current Florida address and new company name. Thank-you. 1#

Page 3Sincerely, David M. Stone, President Photosol, Inc. dba Photographic Solutions 430-G Ansin Blvd. Hallandale, FL 33009 954.458.4744 2#