Exxel/Atmos, Inc. — Hazardous Materials Safety Interpretation

Page 1• • of Transportation U.S.Department Washington, D C 400 Seventh Street. S W 20590 Research and Administration Special Programs OCT 12 1995 Mx. John A. Del Grosso Director of Technical 33 Schoolhouse Road Exxel/Atmos, Inc. Services Somerset, NJ 08873 Dear Mr. Del Grosso: This is in reply to your letter of August 23, 1995, requesting psi), non-aerosol onfirmation that your company's low pressure less than 40 compressed gas dispensing system is not regulated as a Regulations as Packaging CFR Parts under 171-180). the Hazardous Materials information on the contents of the container. You provided no The drawings you enclosed show the system consists of a pleated inner plastic bottle fitted with a valve and surrounded with a rubber sleeve that is placed inside of an outer container. You stated contents of the bot the bottle causes expanded rubber sleeve on the the valve using no the contents to be gas propellant. Based on • expelled information you provided, if the internal container is under 40 psi, and no hazardous material is pressure of the contained in the package, the package is not regulated under the HMR. 171.8. See definition of "hazardous material" in 49 CFR neptutou for your inquiry. I hope this information is Sincerely, Beth 2 Amo#

Page 2Exxel / ATMAS," Inc. matin 33 Schoolhouse Road • Somerset, NJ 08873 • (908) 560-3655 Fax (908) 560-0119 File: 173.115 SC: 518,118 August 23, 1995 DECENET 114125 Mr. Edward Mazzullo U.S. Department of Transportation 400 7th Street Sw Office of Hazardous Materials Standards DHM-10 Washington, DC 20590-0001 Dear Mr. Mazzullo, I called your office today and spoke with Ms. Eileen Martin. She is very knowledgeable, and was courteous and helpful. recommended I write to request a letter of interpretation from She your office for our unique non-aerosol dispensing system. our customers frequently request from us DOT information with is being shipped after filling. Ms. Martin's opinion was that regard to any regulations that may apply to this package when it this dispensing system would not be regulated because of the low operating pressure. I am certain a written response from your office would greatly enhance our information packet we send to our potential customers. ATMOS is which utilizes pressure from an expandable rubber sleeve to a low pressure (less than 40 psi) dispensing system squeeze the products from the container when the dispensing actuator is pressed. used at any time with this dispensing system. There are no compressed gas propellants Enclosed is an information packet for the AIMOS package. I have package. Please call me at (908) 560-3655 if you need anything included detailed article drawings and a description of the ATMOS to complete this request. Thank you for your consideration. I look forward to hearing from you soon. Sincerely irector of Technical Services •#

Page 3ATMOS Overview • Section 1 ATMOS Overview The ATMOS ATMOS is a unique, gas-free aerosol dispensing system that System delivers a variety of benefits: • Safety • Purity • Convenience (360° continuous spray) The cost effective ATMOS package is adaptable to a wide range of product viscosities and is able to accommodate a broad array of outer packaging designs. How ATMOS ATMOS is best described as a package within a package. Works The five step process starts with a polyethylene terephthalate (PET) plastic bottle (the recyclable kind used to make soda bottles) that is pleated and fitted with a valve. The bottle is inserted into a rubber sleeve, placed in an outer container made from recyclable plastic, metal, glass and other materials, then filled with product. The contents are injected under pressure, which expands the bottle and stretches the rubber sleeve. The rubber's propensity to contract provides the pressure to produce the spray. The figure below shows this process. ATMOS* The Continuous Dispensing System O1LI A molded 1. Pleated 2. Inserted into a 3. Fitted with ET bottle is: rubber sleeve a valve 4. Placed in an and filled. outer container Exxel / ATMOS Technical Reference 1-1#

Page 4DATE SYM • S.S. VALVE SPRING - SPRING CUP VALVE PET BARRIER BAG GASKET VALYE DISC ALUMINUM FERRULE - • (EXCRAT AR NOTROS TOLERANCES EXX DECIMAL MATERIAL: SCALI * AS SHOWN FRACTIONAL TITLE POWER ASSEMBL RUNING 40-21 : ANGULAR DATE DRAWING NUMBER 11-9-87 P. I. B. 2. •APPENDIX A#

Page 5[DATE aYM ITEM DESCRIPTION 729฿D MAX. D TITL VALVE FERRULE LADI 2 BARRIER BAG ENERGY SLEEVE 3 MAX. 0,960" - 0. 225".. MAX. -7.050" • • • NOTES I DIMENSIQNS SHOWN ARE FOR REFERENCE - ONLY. TOLERANCES ...EXX 2. DO NOT SCALE DRAWING. DECiMAL. MAXIMUM FILL: SCA 230 ML. PRACTIORA. ##'230 ML. POWE ANGULAR 10 13-88 | DATE DRAWING NUMBER P. I.B.: APPENDIX G#