Tyco Fire Protection Products — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration NOV 162017 1200 New Jersey Avenue, SE Washington, DC 20590 Kym Seth Manager, Hazard Communications & Product Stewardship Tyco Fire Protection Products 2700 Industrial Parkway South Marinette, WI 54143 Reference No. 17-0066 Dear Ms. Seth: This letter is in response to your June 13, 2017, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to classification. You describe your material as a highly-concentrated, water-based surfactant solution with a flash point of 23 cc and a boiling point of greater than 100 cc, which is not capable of sustaining combustion. Specifically, you ask if the material is considered a Class 3 flammable liquid under the HMR. As specified in § 173 .22 of the HMR, it is the shipper' s responsibility to properly class and package a hazardous material. This Office does not normally perform this function. The HMR define a flammable liquid as having a flash point of not more than 60 cc. Per§ 173.120(a)(3), for your material to be exempted from classification as a Class 3 material, it must have a flash point of greater than 35 cc. Since your material does not have a flash point of greater than 35 cc, it is the opinion ofthis Office that the material in question is a Class 3 flammable liquid. If experience or other data indicate that the hazard of flammable liquid or combustible liquid material is greater or less than indicated by the criteria specified in§ 173.120(a) or (b), the Associate Administrator of Hazardous Materials Safety may revise the classification or make the material subject or not subject to the requirements of the HMR (see § 173 .120( d) ). I hope this information is helpful. Please contact us if we can be of further assistance. Sincerely, T. Glenn Foster Chief, Regulatory Review and Reinvention Standards and Rulemaking Division#

Page 2Dodd, Alice (PHMSA) From: Sent: To: Subject: Attachments: INFOCNTR (PHMSA) Wednesday, June 14, 2017 1:41 PM Hazmat Interps FW: Interpretation Letter Request 4221 _001.pdf Hi Shante/Alice, Please submit this as a letter on interpretation. Please let me know if you have any questions. Thanks, Jordan From: Seth, Kimberley [mailto:kseth@tycoint.com] Sent: Tuesday, June 13, 2017 12:45 PM To: PHMSA HM lnfoCenter <PHMSAHMlnfoCenter@dot.gov> Subject: Interpretation Letter Request We recently submitted a sample to determine flammability for purposes of transport. Both the UN and 49CFR standards allow exceptions to the classification of flammable liquids (Class 3). According to the above standards, "liquids with a flashpoint greater than 35°C that do not sustain combustion" are exceptions to the Class 3 definition of a flammable liquid. Our product is a highly concentrated (40% solids) water-based surfactant solution with the following characteristics: • Flash point: 23°C (mainly due to the presence of t-butanol) • Boiling point: >100°C • Does not support sustained combustibility according to the test protocols of the UN and 49CFR standards. (I have attached the test report from Stresau Laboratory) According to the test results, we believe our product is not a flammable liquid despite its flash point lower than the 35°C mentioned in the standards. I would appreciate it if you could give us an official interpretation on whether our product is a Class 3 flammable liquid or not? Kind regards, Kym Seth Kym Seth I Manager, Hazard Communication & Product Stewardship I Tyco Fire Protection Products 2700 Industrial Parkway South, Marinette, WI 54143 USA Tel: 1-715-735-7411 ext. 73522 I Mobile: 1-715-584-7049 I Fax: 1-715-732-3632 kseth@tycoint.com http ://www.tyco.com CONFIDENTIALITY NOTICE: This e-mail message, including any attachments, is for the sole use of the intended recipient(s) and may contain confidential and privileged information or otherwise protected by law. Any unauthorized review, use, disclosure or distribution is prohibited . If you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original message. Any applicable rights to privilege have not been waived. Tyco's vision is Zero Harm to people and the environment. Please consider the environment before printing this message. 1#

Page 3This e-mail contains privileged and confidential information intended for the use of the addressees named above. If you are not the intended recipient of this e- mail, you are hereby notified that you must not disseminate, copy or take any action in respect of any information contained in it. If you have received this e-mail in error, please notify the sender immediately by e-mail and immediately destroy this e-mail and its attachments. 2#

Page 4STRESAU L AB O l< AT C) nY. l hJ C "Excellence in Energetics" N8265 Medley Road , Spooner, WJ 5480 I Phone: 715-635-2777 Fax : 715-635-7979 www.stresau.com June 13, 2017 Ms. Martina Bowen Tyco Fire Protection Products One Stanton Street Marinette, WI 54143 Dear Ms. Bowen: Enclosed please find Laboratory Report# 17064 for Sustained Combustibility Analysis of your sample. Full details are in the enclosed report. An invoice to cover the cost of the laboratory examinations will be sent to your accounting department under separate cover. We appreciate your business and look forward to working with you in the future. If we may be of further assistance, or if you have any questions, please call me at (715) 635-2777. Sincerely, ,.ZZ,...._ ~. €~~""'- Thomas E. Basham Hazardous Materials Manager tb (17064) Over Forty Years of Development• Evaluation • Production of Energetic Devices Classification• Packaging • Testing of Hazardous Materials ISO 9001 :2008 Certified _, Wisconsin Green Tier participant -#

Page 5S RESAU I A D C > R A T C> I ~ Y . I N C • ·"Excellence in Energetics" N8265 Medley Road, Spooner, WI 5480 I Phone: 715-635-2777 Fax: 715-635-7979 www.stresau.com LABORATORY REPORT # 17064 "SUSTAINED COMBUSTIBILTY ANALYSIS" June 13, 2017 for Tyco Fire Protection Products One Stanton Street Marinette, WI 54143 USA Attn: Ms. Martina Bowen Prepared by: 2?v-. L. {S • . ..L Thomas E. Basham Reviewed by Ha&::~ Richard Hoff Compliance Specialist Over Forty Years of Development• Evaluation• Production of Energetic Devices Classification • Packaging • esting of Hazardous Materials ISO 9001 :2008 Certified 1 Wisconsin Green Tier participant#

Page 6STRESAU LABORATORY, INC. June 13, 2017 LABORATORY REPORT# 17064 Page 1 of 7 Prepared for: Tyco Fire Protection Products One Stanton Street Marinette, WI 54143 Subject: "SUSTAINED COMBUSTIBILITY ANALYSIS" 1.0 OBJECT One sample, identified below, was subjected to Sustained Combustibility Analysis in accordance with the United States Department of Transportation's Code of Federal Regulations Tttle 49, Pt 173, App. Hand the United Nation's Transport of Dangerous Goods-Manual of Tests and Criteria, Sixth revised edition (2015) (Test L.2) as requested by Martina Bowen of Tyco Fire Protection Products. Credit Card Payment. 2.0 IDENTIFICATION AND PHYSICAL APPEARANCE FS-221 Product Identifier 780095 Lot# 5202111 17064 Yellow liquid#

Page 7STRESAU LABORATORY, INC. June 13, 2017 LABO RA TORY REPORT # 17064 Page 2 of 7 3.0 TEST CONDUCTED 3.1 SUSTAINED COMBUSTIBILITY TESTING 3.1 .1 SCOPE: This test _ is performed to determine if the tested material will sustain combustion with application and subsequent removal of a flame at temperatures specified by the U.S. D.O.T. and the United Nations criteria. 3.1.2 PROCEDURE: I~; ( ,[ h. f'dll l f:i A11fH~1Hl1x fl If I 1 • t J ~. ii , I The sample is loaded into a Setaflash Open Cup Flashpoint Tester, Model# 01 SF Tester in 2 ml increments and heated to ()CJ O · Cl . at standard pressure. The actual temperature, that the material is tested at, is mathematically determined to correspond with the temperature that the sample would be heated to at standard pressure. A flame is then placed adjacent to the sample in a position specified by the UN as the "Off' position for a 60 second stabilization period. If no sustained combustion occurs in accordance with the test criteria, the flame is placed above the sample in a position specified by the UN as the 'Test" position for an additional 15 seconds. This process is repeated a total of three times or until sustained combustion is achieved. If no sustained combustion is observed with a 60 second stabilization period at hO u · < ;/ , ' ' the process is repeated using a 30 second stabilization period instead of the 60 second stabilization period. If still no sustained combustion occurs in accordance with the test criteria with either of the stabilization periods 60 seconds and 30 seconds, the entire procedure is repeated again with the sample heated to 75 °C. Again, a mathematical adjustment to the test temperature is made to reflect the actual barometric pressure.#

Page 8' STRESAU LABORATORY, INC. June 13, 2017 LABORATORY REPORT# 17064 Page 3 of 7 If no sustained combustion is found at test temperatures of hU (J l or f!J ( :, in the case of a material which has a flash point above 60 °C (140 °F) and below 93 °C (200 °F), if sustained combustion is not found at a test temperature of 5 °C (9 °F) above its flash point, repeat the complete procedure with new portions, but at a test temperature of 20 °C (36 °F) above its flash point. 3.1 .3 CRITERIA: The material must be assessed either as not sustaining combustion or as sustaining combustion. Sustained combustion must be reported at either of the heating times if one of the following occurs with either of the test portions: a) When the test flame is in the "Off' position, the test portion ignites and sustains combustion. b) The test portion ignites while the test flame is in the "Test" position for 15 seconds, and sustains combustion for more than 15 seconds after the test flame has been returned to the "Off' position. 3.1.4 RESULTS 3.14.1 49 C.F.R PART 173 APPENDIX H Sample No. 17064 Date: 06/08/2017 Barometric Pressure: 733.6 mm/Hg Temperature Correction:+ 0.9 °C -· Combustion Combustion 2 3#

Page 9STRESAU LABORATORY, INC. June 13, 2017 LABORATORY REPORT # 17064 Page 4 of 7 Combustion Combustion 2 3 3.1.4.2 49 C.F.R PART 173 APPEND IX H D ISCUSSION : The sample did not ignite and sustain combustion in the "Off' or "Test" position for greater than 15 seconds, at test temperatures of 60 °C. 3.1 .5 U NITED NATIONS The test was also performed at 60.5 °C in accordance with the United Nations Transport of Dangerous Goods Manual of Tests and Criteria, Sixth revised edition (2015) to provide additional information concerning international shipments of the material. 3. 1.5. 1 R ES UL TS Sample No. 17064 Date: 06/08/2017 Barometric Pressure: 733.6 mm/Hg Temperature Correction: + 0.9 °C 1 2 3 Combustion Combustion No Ignition or Sustained Combustion No Ignition or Sustained Combustion 1 2 3#

Page 10STRESAU LABORATORY, INC. June 13, 2017 LABORATORY REPORT# 17064 Page 5 of 7 The sample did not ignite and sustain combustion in the "Off' or "Test" position for greater than 15 seconds, at test temperatures of 60.5 °C. 3.1 .6 49C.F.RPART173APPENDIXH/ I Ill 111\)/ I HI 1· The test was also performed at 75.0 °C in accordance with the Code of Federal Regulations Title 49, Pt. 173, App. Hand the United Nations Transport of Dangerous Goods Manual of Tests and Criteria, sixth revised edition (2015) to provide additional information concerning international shipments of the material. 3.1.6.1 RESULTS Sample No. 17064 Date: 06/08/2017 Barometric Pressure: 733.6 mm/Hg Temperature Correction: + 0.9 °c No Ignition or Sustained Combustion Combustion 1 2 3 No Ignition or Sustained Combustion No Ignition or Sustained Combustion 1 2 3 3.1.6.2 49C.F.RPART 173 APPENDIX H/lJ1 I I I hl!11 <Jfl I i l 'll1,11 11\1' The sample did not ignite and sustain combustion in the "Off' or 'Test" position for greater than 15 seconds, at test temperatures of 75.0 °C.#

Page 11STRESAU LABORATORY, INC. June 13, 201 7 LABORATORY REPORT # 17064 Page 6 of 7 4.0 CONCLUSIONS Based on the test results, the following conclusions were made: 49 C.F.R PART 173 APPENDIX H 1) The material represented by sample # 17064 did not appear to sustain combustion at test temperatures of 60.9 °C or 75.9 °C, which were raised appropriately in order to compensate for the lower than standard barometric pressure as defined by the listed test specifications. Since the Flashpoint was either unknown or not performed by Stresau Laboratory, Inc., the test was not performed at 5 °C and 20 °C above its flashpoint as per the specification. UN ITED NATIONS 2) The material represented by sample # 17064 did not appear to sustain combustion at a test temperature of 61.4 °C, which was raised appropriately in order to compensate for the lower than standard barometric pressure as defined by the listed test specifications. The conclusion represents our interpretations of the test data, as defined by the above listed test specifications. The conclusions contained in this report are for the customer's information purpose only. 5.0 DATASTORAGE The field data for this test is recorded in Data Book 2017-1, and will be filed with Stresau Laboratory's Document Control. No video or photographic documentation was made. 6.0 TEST SERVICES For the benefit of our customers, Stresau Laboratory, Inc., will on occasion, use outside testing services to either expedite or qualify our own testing capabilities.#

Page 12STRESAU LABORATORY, INC. June 13, 2017 LABO RA TORY REPORT # 17064 Page 7 of 7 References Code of Federal Regulations (2015). Title 49, Transportation, Part 173; "Appendix H", National Archives and Records Service, Office of the Federal Register Washington, D.C. United Nations. (2015). Recommendations on the Transport of Dangerous Goods Manual of Tests and Criteria (6th ed.). New York and Geneva: United Nations. pp 363-366.#

Page 13STRESAU L ABOnAIOl<Y. l h J C "Excellence in Energetics" N8265 Medley Road, Spooner, WI 5480 I Phone: 71 5-635-2777 rax: 7 15-635-7979 www.stresau.com Report # 17064 Appendix A EQUIPMENT QUALITY TRACEABILITY FORM Customer: Tyco Fire Protection Products Job Code: 4000 Stresau Report #: HMT 17064 Procedure #: TP 267 Date: June 13, 2017 Report by: Thomas E. Basham Item Mfg. Tester Stopwatch Microprocessor Thermometer Calipers Barometer ERDCO Engineering Corp. Fisher Scientific Omega Engineering, Inc. Mitutoyo Princo Instruments, Inc. Model 01SF 06-662-50 HH21 CD-6"CSX 453 Stresau Equip.# N/A 1937 1136 1613 N/A Quality Status 2 2 2 Attach additional forms if needed Equipment # = Traceable to Stresau Quality System Status: 1 = Not in calibration system 2 = Calibration current as of date listed. 3 = Other. Attach MRR or other documentation as needed FORM # 96C654 Over Forty Years of Development • Evaluation • Production of Energetic Devices Classification• Packaging• Testing of Hazardous Materials ISO 9001 :2008 Certified • Wisconsin Green Tier participant#

Page 14STRESAU LABORATORY , I NC "Excellence in Energetics" N8265 Medley Road, Spooner, WI 54801 Phone: 715-635-2777 Fax: 715-635-7979 www.stresau.com June 13, 2017 Ms. Martina Bowen Tyco Fire Protection Products One Stanton Street Marinette, WI 54143 Dear Ms. Bowen: Enclosed please find Laboratory Report# 17064 for Sustained Combustibility Analysis of your sample. Full details are in the enclosed report. An invoice to cover the cost of the laboratory examinations will be sent to your accounting department under separate cover. We appreciate your business and look forward to working with you in the future. If we may be of further assistance, or if you have any questions, please call me at (715) 635-2777. Sincerely, - ~~.6~ Thomas E. Basham Hazardous Materials Manager tb (17064) Over Forty Years of Development• Evaluation • Production of Energetic Devices Classification • Packaging • Testing of Hazardous Materials ISO 9001:2008 Certified.=., Wisconsin Green Tier participant - ...... _.#

Page 15STRESAU LABORATORY . IN C "Excellence In Energetics" N8265 Medley Road, Spooner, Wl 5480 I Phone: 715-635-2777 Fax: 715-635-7979 www.stresau.com LABORATORY REPORT# 17064 "SUSTAINED COMBUSTIBILTY ANALYSIS" June 13, 2017 for · Tyco Fire Protection Products One Stanton Street Marinette, WI 54143 USA Attn: Ms. Martina Bowen Prepared by: ..:z4....... £". [)_,t. Thomas E. Basham Reviewed by: Ha~ Richard Hoff Compliance Specialist Over Forty Years of Development• Evaluation • Production of Energetic Devices Classification• Packaging• Testing of Hazardous Materials - ISO 9001:2008 Certified_, Wisconsin Green Tier participant - ......#

Page 16STRESAU LABORATORY, INC. June 13, 2017 LABORATORY REPORT # 17064 Page 1of7 Prepared for: Tyco Fire Protection Products One Stanton Street Marinette, WI 54143 Subject: "SUSTAINED COMBUSTIBILITY ANALYSIS" 1.0 OBJECT One sample, identified below, was subjected to Sustained Combustibility Analysis in accordance with the United States Department of Transportation's Code of Federal Regulations Title 49, Pt 173, App. Hand the United Nation's Transport of Dangerous Goods-Manual of Tests and Criteria, Sixth revised edition (2015) (Test L.2) as requested by Martina Bowen of Tyco Fire Protection Products. Credit Card Payment. 2.0 IDENTIFICATION AND PHYSICAL APPEARANCE ~~~~~~~~~~~~~~~~~~~~~ FS-221 Product Identifier 780095 Lot# 5202111 17064#

Page 17STRESAU LABORATORY, INC. June 13, 2017 LABORATORY REPORT # 17064 Page 2 of 7 3.0 TEST CONDUCTED 3.1 SUSTAINED COMBUSTIBILITY TESTING 3.1.1 SCOPE: This test_is performed to determine if the tested material will sustain combustion with application and subsequent removal of a flame at temperatures specified by the U.S. D.O.T. and the United Nations criteria. 3.1 .2 PROCEDURE: 49 CFR Part 173 Appendix H Uf\J Test Method L.2 The sample is loaded into a Setaflash Open Cup Flashpoint Tester, Model# 01 SF Tester in 2 ml increments and heated to 60.0 "C/GO ~) "C. at standard pressure. The actual temperature, that the material is tested at, is mathematically determined to correspond with the temperature that the sample would be heated to' at standard pressure. A flame is then placed adjacent to the sample in a position specified by the UN as the "Off' position for a 60 second stabilization period. If no sustained combustion occurs in accordance with the test criteria, the flame is placed above the sample in a position specified by the UN as the "Test" position for an additional 15 seconds. This process is repeated a total of three times or until sustained co.mbustion is achieved. If no sustained combustion is observed with a 60 second stabilization period at 60 o "C/GO 5 ''C . the process is repeated using a 30 second stabilization period instead of the 60 second stabilization period. If still no sustained combustion occurs in accordance with the test criteria with either of the stabilization periods 60 seconds and 30 seconds, the entire procedure is repeated again with the sample heated to 75 °C. Again, a mathematical adjustment to the test temperature is made to reflect the actual barometric pressure.#

Page 18STRESAU LABORATORY, INC. · June 13, 2017 LABO RA TORY REPORT # 17064 Page 3 of 7 If no sustained combustion is found at test temperatures of 60.0 °C or 75 °C, in the case of a material which has a flash point above 60 °C (140 °F) and below 93 °C (200 °F), if sustained combustion is not found at a test temperature of 5 °C (9 °F) above its flash point, repeat the complete procedure with new portions, but at a test temperature of 20 °C (36 °F) above its flash point. 3.1.3 CRITERIA: The material must be assessed either as not sustaining combustion or as sustaining combustion. Sustained combustion must be reported at either of the heating times if one of the following occurs with either of the test portions: a} When the test flame is in the "Off' position, the test portion ignites and sustains combustion. b) The test portion ignites while the test flame is in the "Test" position for 15 seconds, and sustains combustion for more than 15 seconds after the test flame has been returned to the "Off' position. 3.1.4 RESULTS 3.1.4.1 49 C.F.R PART 173 APPENDIX H Sample No. 17064 Date: 06/08/2017 Barometric Pressure: 733.6 mm/Hg Temperature Correction: + 0.9 •c Combustion Combustion 2 3#

Page 19STRESAU LABORATORY, INC. June 13, 2017 LABORATORY REPORT # 17064 Page 4 of 7 1 2 3 Combustion l Combustion 3.1.4.2 49 C.F.R PART 173 APPENDIX H DISCUSSION: The sample did not ignite and sustain combustion in the "Off' or "Test" position for greater than 15 seconds, at test temperatures of 60 °C. 3.1.5 UNITED NATIONS The test was also performed at 60.5 °C in accordance with the United Nations Transport of Dangerous Goods Manual of Tests and Criteria, Sixth revised edition (2015) to provide additional information concerning international shipments of the material. 3.1 .5.1 RESULTS Sample No. 17064 Date: 06/08/2017 Barometric Pressure: 733.6 mm/Hg Temperature Correction:+ 0.9 °C 1 2 No Ignition or Sustained Combustion Combustiori l l 1 2 3 Combustion Combustion#

Page 20STRESAU LABORATORY, INC. June 13, 2017 LABORATORY REPORT# 17064 Page 5 of 7 The sample did not ignite and sustain combustion in the "Off' or "Test" position for greater than 15 seconds, at test temperatures of 60.5 °C. 3.1.6 49 C.F .R PART 173 APPENDIX H/UJ'1!1 EJ) i 'il\rnm~; Tt : ~·, 1 L .2 The test was also performed at 75.0 °C in accordance with the Code of Federal Regulations Title 49, Pt. 173, App. Hand the United Nations Transport of Dangerous Goods Manual of Tests and Criteria, sixth revised edition (2015) to provide additional information concerning international shipments of the material. 3.1.6.1 RESULTS Sample No. 17064 Date: 06/08/2017 Barometric Pressure: 733.6 mm/Hg Temperature Correction:+ 0.9 °C No Ignition or Sustained Combustion 1 2 3 Combustion Combustion 3.1.6.2 49 C.F.R PART 173 APPENDIX H/U1'1: f ED l\J/1l IUW:. l f<) i L 2 DISC\ iSS J ON The sample did not ignite and sustain combustion in the "Off" or "Test" position for greater than 15 seconds, at test temperatures of 75.0 °C.#

Page 21STRESAU LABORATORY, INC. June 13, 2017 LABO RA TORY REPORT# 17064 Page 6of7 4.0 CONCLUSIONS Based on the test results, the following conclusions were made: 49 C.F.R PART 173 APPENDIX H 1) The material represented by sample # 17064 did not appear to sustain combustion at test temperatures of 60.9 °C or 75.9 °C, which were raised appropriately in order to compensate for the lower than standard barometric pressure as defined by the listed test specifications. Since the Flashpoint was either unknown or not performed by Stresau Laboratory, Inc., the test was not performed at 5 °C and 20 °C above its flashpoint as per the specification. U NITED NATIONS 2) The material represented by sample # 17064 did not appear to sustain combustion at a test temperature of 61.4 °C, which was raised appropriately in order to compensate for the lower than standard barometric pressure as defined by the listed test specifications. The conclusion represents our interpretations of the test data, as defined by the above listed test specifications. The conclusions contained in this report are for the customer's information purpose only. 5.0 DATASTORAGE The field data for this test is recorded in Data Book 2017-1 , and will be filed with Stresau Laboratory's Document Control. No video or photographic documentation was made. 6.0 TEST SERVICES For the benefit of our customers, Stresau Laboratory, Inc., will on occasion, use outside testing services to either expedite or qualify our own testing capabilities.#

Page 22STRESAU LABORATORY, INC. June 13, 2017 LABO RA TORY REPORT # 17064 Page 7 of 7 References Code of Federal Regulations (2015). Title 49, Transportation, Part 173; "Appendix H", National Archives and Records Service, Office of the Federal Register Washington, D.C. United Nations. (2015). Recommendations on the Transport of Dangerous Goods Manual of Tests and Criteria (6th ed.). New York and Geneva: United Nations. pp 363-366.#

Page 23S TR E SAU LAB O RATORY . I NC "Excellence in Energetics" N8265 Medley Road, Spooner, WI 54801 Phone: 715-635-2777 Fax: 715-635-7979 www .stresau.com Report # 17064 Appendix A EQUIPMENT QUALITY TRACEABILITY FORM Customer: Tyco Fire Protection Products Job Code: 4000 Stresau Report#: HMT 17064 Procedure #: TP 267 Date: June 13, 2017 Report by: Thomas E. Basham Item Mfg. Tester Stopwatch Microprocessor Thermometer Calipers Barometer ERDCO Engineering Corp. Fisher Scientific Omega Engineering, Inc. Mitutoyo Princo Instruments, Inc. Model 01SF 06-662-50 HH21 CD-6"CSX 453 Stresau Equip.# N/A 1937 1136 1613 N/A Quality Status 1 2 2 2 Attach additional forms if needed Equipment # = Traceable to Stresau Quality System Status: 1 = Not in calibration system 2 = Calibration current as of date listed. 3 = Other. Attach MRR or other documentation as needed FORM # 96C654 Over Forty Years of Development• Evaluation • Production of Energetic Devices Classification • Packaging • Testing of Hazardous Materials - ISO 9001 :2008 Certified _, Wisconsin Green Tier participant '!l!llllllll!fo' Mllil!iii;O ......#