Airborne Labs International, Inc. — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department 1200 New Jersey Avenue, SE Materials Safety Pipeline and Hazardous Washington, DC 20590 Administration JUN 1 5 2017 Mr. Tony Amato Technical Program and Safety Manager Airborne Labs International, Inc. 22C World's Fair Drive Somerset, NJ 08873 Reference No. 17-0009 Dear Mr. Amato: This letter is in response to your January 30, 2017, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to cylinders. Specifically, you reterence numerous requirements in Part 173 and ask whether a pressure relief device (PRD) is required when shipping "UN1080, Sulfur hexafluoride, 2.2" or "UN1013, Carbon dioxide, 2.2" in Department of Transportation (DOT) Specification 3E-1800 sample cylinders with volumes of 150cc, 300cc, and 500cc, respectively. When shipping Division 2.2 non-flammable gases such as "UN1080, Sulfur hexafluoride, 2.2" or "UN1013, Carbon dioxide, 2:2" in DOT-3E-1800 sample cylinders, a PRD is required in accordance with the general requirements for cylinders in § 173.301(f). However, § 173.301(F)(7) provides an exception for smaller quantities of carbon dioxide shipped in DOT-3E cylinders. This paragraph excepts DOT-3E cylinders up to 12 inches in length containing less than 8 ounces (236.5 cc) of carbon dioxide from the PRD requirement. I hope this information is helpful. Please contact us if we can be of further assistance. Sincerely, TAken Fasten T. Glenn Foster Chief, Regulatory Review and Reinvention Branch Standards and Rulemaking Division#

Page 2Andrews §/ 73.301 Gener Dodd, Alice (PHMSA) From: INFOCNTR (PHMSA) Sent: Tuesday, January 31, 2017 11:57 AM To: Hazmat Interps Subject: FW: interpretation 49CFR Attachments: 02101DOTCompliant640x640v2.jpg Importance: High Hi Shante/Alice, Please submit this as a letter of interpretation. Mr. Amato spoke with Eamonn. Please let me know if you have any questions. Thanks, Jordan From: Tony Amato [mailto:Tony.Amato@AIRBORNELABS.COM] Sent: Monday, January 30, 2017 1:51 PM To: INFOCNTR (PHMSA) < INFOCNTR.INFOCNTR@dot.gov> Subject: interpretation 49CFR Importance: High To Whom It May Concern: was speaking to your Hazmat Specialist amonn He helped me with my question on Sulfur Hexafluoride and Carbon dioxide I need a written interpretation for this ruling when shipping UN 1080 in a 3E1800 sample cylinder. Also for Carbon dioxide UN 1013 He said to send an email to this address; The size of the cylinder are 150cc; 300cc & 500cc double ended cylinder see attached picture Does the cylinder valve need a PRD ( pressure relief device ) according to §173.301 — General requirements for shipment of compressed gases and other hazardous materials in cylinders, UN pressure receptacles and spherical pressure vessels §173.301(f) §173.301(f)(2) §173.301(f)(5)i §173.301(f)(5) §173.304a(2) Regards Tony Amato 1#

Page 3Technical Program & Safety Manager 22C World's Fair Drive Airborne Labs International, Inc. T: 732-302-1950 Somerset, NJ 08873 F: 732-302-3035 Airborne Labs International ISO/IEC 17025:2005 Accredited Laboratory Your opinion matters Please visit our website to learn more about our professional services and products. 2#