Peerless Coatings, Inc. — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S Department 400 Seventh Street, S.W. Washington, D.C. 20590 Research and Special Programs Administration NOV | 6 1998 Mr. Ronnie Screws Compliance Officer Ret. No. 98-0302 Peerless Coatings, Inc. 1611 22nd Street S.E. Cullman, AL 35055-5465 Dear Mr. Screws: This is in response to your letter dated October 2, 1998, regarding the applicability of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) to shipments of flammable liquids on your company aircraft. The Department of Transportation governs the transportation of hazardous materials in interstate, foreign, and intrastate commercial movements. Hazardous materials transported aboard your company aircraft are in commerce, and are subject to the HMR. The purpose and scope of the HMR may be found in § 171.1. I hope this satisfies your inquiry. If this office can be of further assistance, please contact us. Sincerely, Delmer F. Billings Chief, Standards Development Office of Hazardous Materials Standards -#

Page 2Filé: 175 RMC Radiation Management Consultants March 19, 1998 Edward Mazzullo Director Office of Hazardous Materials Standards Research and Special Programs Administration US Department of Transportation 400 7' Street, S.W. Washington D.C. 20590 Dear Director: In the course of my work as an emergency medical consultant to the nuclear power and chemical industries, I have been confronted with, on numerous occasions the following dilemma. Many medical helicopter programs (MED EVAC) pilots and directors have advised me that they do not/will not transport a patient who is contaminated with ANY level of radioactive contamination; even if this patient is in dire need of lifesaving transport (flight) to a trauma center. I am furthermore advised that flying this type of patient is "prohibited by the FAA." allowed. The whity omanies, with repres moud oni action set, ahibited or concerned that eventually an incident will occur which will result in an — unnecessary death. Thank you for your attention with this matter. Please contact me at (215) 824-1300 if you require any further information. Sincerely, Gil Cosnett Clinical Instructor GC:slp 3021 Darnell Road • Philadelphia, PA 19154 • (215) 824-1300 • FAX# (215) 824-1371 ....#

Page 3Nelson PEERLESS 5173.22 98-0302 Peerless Coatings, Inc. 1611 22nd St. S.E., Cullman, AL 35055-5465 (256) 734-5000 174. October 2, 1998 Mr. Edward Mazzullo, DHM-10 Research and Special Projects Administration (RSPA) Office of Hazardous Material Standards 400 Seventh Street Southwest Washington, DC 20590 Dear Mr. Mazzullo: My name is Ronnie Screws, I am the Compliance Officer for Peerless Coatings, Inc., a manufacturer of industrial coatings. Peerless Coatings, Inc. also owns a Cessna 414 aircraft. My direct supervisor has asked me to determine if transporting 0 - 10 gallon amounts of a flammable liquid (UN1263) on the above mentioned company aircraft falls under DOT regulations. Please forward a written interpretation of this situation with regards to current DOT regulations. Your help would be greatly appreciated. /lea Respectfully, • 1S piratingen Ronnie Screws Compliance Officer 8 RS/km paint related material UN 1263 3öL Max PEI,I, III Core E seat 3, 171.1 13' EX. 173.150 pla , 73,201 /#