Kidde Technologies, Inc. — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation 1200 New Jersey Avenue, SE Washington, D.C. 20590 Pipeline and Hazardous Materials Safety Administration MAR 0 1 2016 Mr. Brett Standifer Manager, Fire Extinguishing Engineering Kidde Technologies, Inc. 4200 Airport Drive NW Wilson, NC 27896 Ref. No.: 15-0200 Dear Mr. Standifer: This letter is in response to your August 7, 2015, request for clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the marking requirements for fire extinguishers. Specifically, you ask if the following are considered permanent markings in accordance with § 178.47(g): Metal hand stamp with low stress type stamps Laser marking or engraving Rubber stamp with permanent marking ink Rubber stamp with permanent marking ink overcoated with clear paint Vibro hand engraving Dot Peen machine engraving Electro-chemical etching/marking Metal stamping on a metal label and the label affixed to the article with adhesive permanent attachment or on a metal nameplate and permanently secured to the container by As required in § 178.47(g), markings must be stamped plainly and permanently on a means other than soft solder. All of the methods you described could be permitted as permanent markings on the cylinders provided they do not compromise the integrity of the cylinder and the markings are legible. I hope this information is helpful. Please contact us if we can be of further assistance. Sincerely, Tester T. Glenn Foster Chief, Regulatory Review and Reinvention Branch Standards and Rulemaking Division#

Page 2Andrews 118.47 Goodall, Shante CTR (PHMSA) From: Geller, Shelby CTR (PHMSA) Sent: To: Wednesday, October 07, 2015 11:32 AM Hazmat Interps Subject: FW: Interpretation of 49 CFR 178.47 Attachments: DOT Interpretation Request Permanent Marking.docx Dear Shante and Alice, Forwarded is a request for a formal letter of interpretation. Thanks, Shelby From: Fazzio, Mark UTAS [mailto:Mark.Fazzio@utas.utc.com] To: PHMSA HM InfoCenter Sent: Tuesday, October 06, 2015 5:00 PM Subject: Interpretation of 49 CFR 178.47 Dear Sir or Madam, Please see the attached interpretation request of 49 CFR 178.47. Thank you, Mark Fazzio - Senior Mechanical Engineer - Sensors & Integrated Systems UTC AEROSPACE SYSTEMS 4200 Airport Dr. NW, Wilson, NC 27896 Tel: +1 252 246 7910 Fax: +1 252 246 8415 mark.fazzio@utas.utc.com www.utcaerospacesystems.com companies. If you are not the intended recipient please 1) do not disclose, copy, distribute or use this message or its contents, 2) advise the sender by CONFIDENTIALITY WARNING: This message may contain proprietary and/or privileged information of UTC Aerospace Systems and its affiliated return e-mail, and 3) delete all copies (including all attachments) from your computer. Your cooperation is greatly appreciated.#

Page 3UTC Aerospace Systems August 7, 2015 Associate Administrator for Hazardous Material Safety Pipeline and Hazardous Materials Safety Administration U.S. Department of Transportation East Building 1200 New Jersey Avenue, SE Washington, D.C. 20590-0001 Attention: General Approvals and Permits, PHH-31 Subject: Interpretation of 49 CFR 178.47 Dear Sir/Madam: Kidde Technologies, doing business as Kidde Aerospace & Defense (KAD), a long time mausaturer of resture vessel used for aira, and mitary vehicle fire extinguishing is nameplate permanently secured to the container by means other than soft solder" "Marking. Markings must be stamped plainly and permanently on a permanent attachment or on a metal Kidde is requesting interpretation to the above paragraph, specifically to the acceptable methods of "permanent marking". The following methods are used in our facility. We are asking for clarification if these are considered permanent: Metal Hand Stamp, with low stress type stamps Laser marking or engraving Rubber stamp with permanent marking ink Rubber stamp with permanent marking ink then over coated with a clear paint. Vibro hand engraving Dot peen machine engraving Electro-chemical etching/marking Metal stamping on a metal label and the label affixed to the article with adhesive. Please advise if this is an accurate interpretation of 49 CFR 178.47(9) If any further information is needed, please contact any of the below individuals Brett Standifer - brett.standifer@hs.utc.com, 252-246-7955 Mark Fazzio - mark.fazzio@hs.utc.com, 252-246-7910 Eric Starkey - charles.starkey@hs.utc.com, 252-246-7930 Thank you, Brett Standifer Manager, Fire Extinguishing Engineering, Kidde Aerospace & Defense 4200 Airport Drive NW Kidde Technologies, Inc. Tel 252 246 7955 Wilson, NC 27896 http://utcaerospacesystems.com/sites/kiddeaerospace/Pages/home.aspx#