Waysmos USA — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Avenue, SE Washington, DC 20590 August 16, 2023 Mike Kiamanesh Waysmos USA 2032 Robert Browning St. Austin, TX 78723 Reference No. 23-0032 Dear Mr. Kiamanesh: This letter is in response to your March 24, 2023, letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the transport of a liquid fire suppression agent that you manufacture. In your letter, you state that the material is not a hazardous material and you provide a safety data sheet as supporting documentation. Further, you state that you would like to transport the liquid material in a non-DOT specification cylinder instead of your current practice of using a 55-gallon steel drum. You note that internationally these cylinders are used to transport pressurized liquified gases such as other fire suppression agents. You state that this change in manner of transport is to facilitate filling of the associated fire suppression system upon delivery. Specifically, you request confirmation that this shipment is not subject to the requirements of the HMR and that the use of these cylinders is permitted. In accordance with § 173.22, it is the shipper s responsibility to properly classify a hazardous material. If you have determined that the liquid fire suppression agent is not a hazardous material in accordance with applicable HMR criteria, then it is not subject to the HMR and may be transported in the packages you noted without restriction from the HMR. I hope this information is helpful. Please contact us if we can be of further assistance. Sincerely, Dirk Der Kinderen Chief, Standards Development Branch Standards and Rulemaking Division#

Page 2Casey 23-0032 From: INFOCNTR (PHMSA) To: Hazmat Interps Subject: FW: Request for interpretation - Using liquid in gas cylinder Date: Friday, March 31, 2023 10:43:15 AM Attachments: 926L-6mm cylinder.pdf SDS-FK-5-1-12-US-Version-4.1-2021-05-07.doc (5).pdf Hello, Please see attached and below request for letter of interpretation. Also here is the mailing address: Michael Kiamanesh 2032 Robert Browning St, Austin, TX 78723 737-999-3367 Thanks, Jonathon, HMIC From: Mike Kiamanesh <mike@waysmosusa.com> Sent: Friday, March 24, 2023 2:03 PM To: INFOCNTR (PHMSA) <INFOCNTR.INFOCNTR@dot.gov> Subject: Request for interpretation - Using liquid in gas cylinder CAUTION: This email originated from outside of the Department of Transportation (DOT). Do not click on links or open attachments unless you recognize the sender and know the content is safe. Hi DOT, I am interested in importing a fire suppression agent that we manufacture called FK-5-1-12 (SDS attached), in non-dot approved gas cylinders (drawing of cylinder attached). The molecule FK-5-1-12 as you can see on the SDS is not considered hazmat, right now the most common way of transporting it is as general cargo in 55 gallon steel drums. Why we want to use the cylinders is because our customers want a larger bulk packaging where they do not need to switch containers (drums) as much when filling their fire suppression system cylinders. For reference the drums each hold about 250kg of the FK-5-1-12 while the cylinder we want to use holds 1000kgs. These cylinders are used internationally (not in USA) to bulk transport pressurized liquified gases, such as another fire suppression agent HFC-227ea. We just want to start using them in the USA for moving this non pressurized non hazmat bulk liquid fire suppression agent. Let me know anything else you need from me. I am available anytime for a call as well.#

Page 3Regards Mike 737-999-3367#

Page 4Safety Data Sheet Section 1 – Chemical Product and Company Identification Product Name FK-5-1-12 Chemical Name 1,1,1,2,2,4,5,5,5-Nonafluoro-4-(trifluoromethyl)-3-pentanone Synonym FLUOROKETONE, Perfluoro(2-Methyl-3-Pentanone), NOVEC1230™ Product Use Fire extinguishing agent Manufacturer Address Shanghai Waysmos Fine Chemical Co., Ltd. 388 Liangle Road, Laogang, Pudong New Area, Shanghai, China Email sales@waysmos.com Telephone +86-571-85069383 Fax +86-571-85069385 Section 2 –Hazard Identification Hazard classification This material is not considered hazardous by the OSHA Hazard Communication Standard (29 CFR 1910.1200) Hazard pictograms Signal word Warning Hazard statements Precautionary statements Other Hazard H412: Harmful to aquatic life with long lasting effects. P261: Avoid breathing vapours. P273: Avoid release to the environment. P280: Wear protective gloves/protective clothing. Overheating and over pressurizing may cause gas release or violent container bursting. Section 3 – Composition/Information on Ingredients Ingredient name CAS No. %(weight) 1,1,1,2,2,4,5,5,5,-Nonafluoro-4-(t rifluoromethyl)-3-pentanone 756-13-8 ≥99. 0 Section 4 – First Aid Measures Revision date: May.7,2021 Version 4.1 1#

Page 5Safety Data Sheet Inhalation Skin Eyes Ingestion Note to physician Remove victim to fresh air and keep at rest in a position comfortable for breathing. If not breathing, if breathing is irregular or if respiratory arrest occurs, provide artificial respiration or oxygen by trained personnel. If unconscious, place in recovery position and get medical attention immediately Remove and isolate contaminated clothing and shoes. Wash immediately with plenty of soap and water. Get medical attention if frostbitten by liquid or if irritation persists Immediately flush with large amounts of water for at least 15 minutes Get medical attention if irritation occurs DO NOT induce vomiting unless instructed to do so by a physician. Get medical attention immediately if symptoms develop. Immediate medical attention is not required When symptoms persist or in all cases of doubt seek medical advice Section 5 – Fire Fighting Measures Extinguishing media Special hazards arising from the substance or mixture Special protective equipment for firefighters Product is a fire extinguishing media. Use media appropriate for surrounding material Thermal decomposition may cause toxic products Containers may explode in heat of fire. Wear self-contained breathing apparatus with a full face-piece operated in positive pressure mode and chemical-protective clothing. Prevent fire extinguishing water from contaminating surface water or the ground water system Section 6 – Accidental Release Measures Personal precautions, protective equipment and emergency procedures Environmental precautions Methods and material for containment and cleaning up Reference to other SECTIONs Refer to section 8 of SDS for personal protection details. Wear mask and appropriate protective clothing for daily operation. Prevent skin and eye contact. Keep unprotected persons away. If outside do not approach from downwind. Do not discharge into drains/surface waters/groundwater Evacuate area. Keep upwind. Stop leak if without risk. Ventilate area especially low places remove open flames and heating elements. Disperse it with floor level forced air See SECTION 7 for information on safe handling See SECTION 8 for information on personal protection equipment See SECTION 13 for information on disposal Section 7 – Handling and Storage Revision date: May.7,2021 Version 4.1 2#

Page 6Safety Data Sheet Handling Storage Avoid direct contact with the substance. Wash thoroughly after handling. Ensure there is sufficient ventilation of the area. Do not handle in a confined space. Avoid the formation or spread of mists in the air. Contents may be under pressure, open carefully. Do not breathe thermal decomposition products. For industrial or professional use only. Do not eat, drink or smoke when using this product. Do not drag, slide or roll containers. Do not drop containers or permit them to strike against each other. Never apply flame or localized heat directly to any part of the container. Store in dry, cool, well ventilated area. Keep container tightly closed. Keep out of direct sunlight and ultraviolet, keep away from incompatible materials, water, keep away from sources of heat or ignition. Containers should be properly stored and secured to prevent falling or being knocked over. Section 8 –Exposure Controls/Personal Production 8.1 Control parameters Occupational exposure limit values 8.2 Exposure controls Appropriate engineering controls 150 ppm, 8 hr TWA Personal protective equipment Respiratory Protection Skin Protection Eye Protection Environmental exposure controls Use only with adequate ventilation. Use process enclosures, local exhaust ventilation or other engineering controls to keep worker exposure to airborne contaminants below any recommended or statutory limits Self-contained breathing apparatus or full facepiece supplied-air respirator must be available in case of emergency. Wear protective gloves/clothing to prevent contact Safety glasses/chemical splash goggles Do not empty into drains Section 9 – Physical and Chemical Properties 9.1 Information on basic physical and chemical properties Appearance Liquid Color colorless Odour Low odor pH Not available Melting point -108°C Boiling point 49 °C Flash point Not available Evaporation rate > 1(BUOAC = 1.0) Flammability (solid, gas) Not flammable Upper/lower flammability or Not available explosive limits Vapour pressure 40.4 Kpa (25°C) Specific gravity（H2O=1 1.6 g/cm3 Solubility(ies) Not available Partition coefficient: n-octanol/water log Kow = 2.11 Revision date: May.7,2021 Version 4.1 3#

Page 7Safety Data Sheet Auto-ignition temperature Not available Viscosity 0.6 mPa.s (25°C) Section 10 – Stability and Reactivity Reactivity Chemical stability Possibility of hazardous reactions Conditions to avoid Incompatible materials Hazardous decomposition products Stable under recommended storage and handling conditions (see SECTION 7, handling and storage) Stable under normal conditions of use No known hazardous reactions Keep away from heat and ignition sources. Protect from sunlight Strong oxidizing materials, Strong acids and bases Thermal decomposition can lead to release of irritating or toxic gases/vapors: carbon oxides, hydrogen fluoride Section 11 – Toxicological Information 11.1 Information on toxicological effects Acute Toxicity Ingredient name LD50 Oral(rat) LD50 Dermal (rat) LC50 Inhalation (rat) 1,1,1,2,2,4,5,5,5-Nonafluoro-4-(triflu oromethyl)-3-pentanone > 2,000 mg/kg > 2,000 mg/kg >1,227 mg/l/4h (>10% by volume) Skin corrosion/irritation No information available Serious eye damage/irritation No information available Respiratory or skin sensitization No information available Germ cell mutagenicity No information available Reproductive toxicity No information available STOT-single exposure No information available STOT-repeated exposure No information available Aspiration hazard No information available Carcinogenicity Not listed as a carcinogen by NTP, IARC, or OSHA Section 12 – Ecological Information Toxicity (Ecotoxicity Fish, LC 50 ) >1200 mg/l (Zebra Fish, 96h) Degradability Atmospheric lifetime is approximately 0.014 years(5 days) Bioaccumulation/ Accumulation No data available Mobility in Environmental Media Not available Other adverse effects Ozone Depletion Potential (CFC 11 = 1.0): 0.00 Global Warming Potential (CO2 = 1.0): 1.00 Section 13 –Disposal Considerations Waste Disposal Method Disposal must be made according to local and national regulations. Empty containers should be taken for local recycling, recovery or waste disposal. Revision date: May.7,2021 Version 4.1 4#

Page 8Safety Data Sheet Section 14—Transport Information ITEM LAND ☐ EU: ADR/RID ☐ US: DOT SEA IMDG AIR ICAO / IATA UN-Number General cargo General cargo General cargo Packaging Group Special precautions for user None determined Section 15—Regulatory Information 15.1 Safety, health and environmental regulations/legislation specific for the substance or mixture Listed in international inventories: Ingredient name TSCA DSL NDSL ELIN CS ENCS CHIN A KECL PICC S AICS 1,1,1,2,2,4,5,5,5-Nonafluoro -4-(trifluoromethyl)-3-penta none YES YES NDA YES YES YES YES YES YES Section 16 – Other Information In accordance with good practices of personal cleanliness and hygiene handle with the care and avoid unnecessary contact with this product. This information is being supplied to you under OSHA Hazard Communication Standard 29 CFR 1910.1200 and is offered in good faith as typical values and not as a product specification. The information contained herein is based on the data available to us and is believed to be true and accurate. No warranty expressed or implied regarding the accuracy of this data. The hazards connected with the use of the material or the results to be obtained from the use thereof are made. Shanghai Waysmos Fine Chemical Co., Ltd. assumes no responsibility for damage or injury from the use of the product described herein Revision date: May.7,2021 Version 4.1 5#

Page 9Hole site Sprayer position Hole site -#