Ms. Britt-Marie Butler — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department 400 Seventh Street, S W. Research and Washington, D C 20590 Special Programs Administration JAN | 4 1999 Ms. Britt-Marie Butler Husqvarna AB Reference No. 98-0336 S-433 81 Jonsered SWEDEN - Dear Ms. Butler: This is in response to your letter asking if your packaging, a 6-liter UN 3H1 non-removable head plastic jerrican pin-mounted (joined) to a non-specification 2.5 liter plastic blow-molded bottle, would qualify as a combination packaging in the United States. The answer is no. As defined in 49 CFR 171.8, a combination packaging means one or more inner packagings secured in a non-bulk outer packaging; a condition your joined packagings do not meet. Instead, your jerrican meets the definition in § 171.8 for a single packaging and must be tested and approved in accordance with the UN specification requirements. Because the packagings are pin-mounted, we also recommend that they be drop tested separately and after being joined together. I hope this satisfies your request. Sincerely, dward I. Mazzul Director, Office of Hazardous Materials Standards#

Page 2Tuck H Husqvarna 8343 ze 178.509,171.8 98-0336 The Research and Special Programmes Administration Office of Hasardous Materials Technology DHM/20 400 7th Street, S.W. (South West) Washington D.C. 20590 USA Datum/Date October 14th, 1998 Vår ref./Our ref. B-M. Butler Er ref./Nour ref. Dear Sirs, In order to reach the right authority for the below subject we have received valuable help from the US Embassy in Stockholm. Mr. Jerry Fulmecci at the Dept. of Transport informed us that we should address our question to you. Husqvarna AB is a company within the Electrolux-group, developing, producing and marketing forestry and garden products. After market is an important, growing sector including for example protective clothing, helmets, boots etc. The combi can, 6 1 petrol + 2,5 1 oil, is one of our most popular products. The can is approved of according to the UN-norms. We are a seriously working firm and would only sell approved products. As far as we understand, the UN-norms are accepted all around the world and therefore we take it, that our daughter company in the US, Husqvarna Forest & Garden, Charlotte, NC, would be allowed to sell it. We are enclosing the UN-Certificate, issued by the Swedish test institute, SP, the test report issued by Borealis, drawings and other information issued by the manufacturer, Lear Corporation Gnosjöplast AB, for your information. We ask you kindly to look into this matter and to let us know whether our certification papers would be sufficient for selling the combi can in the US. Also, in case of a positive answer, would this apply for all states or do you have different regulations for various states? We would appreciate having your opinion in this matter sent to the following address: Husqvarna AB, Att.: Britt-Marie Butler, S-433 81 JONSERED, Sweden. or (preferably) to the following fax no.: 0046-31-949118. Looking forward to a positive answer and many thanks in advance. Best regards, • i Butler#

Page 3: * gWEDAC SPE CERTIFICATE ENG-FORE issued by an Accredited Certification Body No. 11 79 01 REDITER EN 45011 1002 Packaging for dangerous goods Holder of certificate Nordic Forestry Equipment AB, Falun, Sweden. Product Plastics jerrican with non-removable head, 3H1. Capacity: 6 I. Description: Combi jerrican 6+2.5. Material: Borealis HE 8253. Tare weight: 740 g. External dimensions (L x W x H): 240 x 160 x 330 mm.: Screw cap: Hostaform HDPE S9244. Gasket: O-ring and gasket. Manufacturing plant Lear Corporation Gnosjöplast AB, Gnosjö, Sweden. Decision SP issues the certification of the product described above on the following legal basis: • Swedish Rescue Services Board Statutes SRVFS 1996:2 and 1996:3, • National Maritime Administration Statutes SJÖFS 1995:2, • Board of Civil Aviation Statutes LFS 1984:2, • Swedish Ordinance SFS 1982:923 for the transport of dangerous goods Marking Each product, manufactured in accordance with Certification Rules SPCR 059, and which is subjected to manufacturing inspection according to Agreement No. 130-82-351, may be marked as follows: 3H1/Y1.0/200/YR/S/SP-11 79 01-ID where * to be lead the mation a decided dy the mame year e manufacture, and Notes The underlying documents for certification, limitations with regard to substances and transport conditions and other relevant information are found in Appendix 1 to this Certificate. This Certificate is valid until and including 30 September 2003. • Borås, 3 September 1998 SP Swedish National Testing and Research Institute Wif Mitmy Depay Head of Certification Dept. Technical Officer#

Page 43 September 1998 SP Appendix 1 ORSENT to CERTIFICATE No. 11 79 01 Regulations supporting the certification • ADR, European Agreement concerning the International Carriage of Dangerous Goods by Road. RID, International Regulations on the Transport of Dangerous Goods by Rail. • IMDG, International Maritime Dangerous Goods Code, for sea transport. • ICAO Technical Instructions for the Safe Transport of Dangerous Goods by Air, and IATA Dangerous Goods Regulations, for air transport. • UN Recommendations on the Transport of Dangerous Goods. Basis MTU98020 Test report Date Issued by 1998-09-03 Scope Borealis AIS Mandatory type testing Substance and transport limitations In addition to the conditions stated in the applicable regulations the following limitations apply for the filling substance: Type of contents Liquid substances which do not adversely affect the packaging materials. Compatibility testing has been carried out according to the ADR and RID with the following model liquid: White spirit. Permitted packing groups II and III. Maximum allowable vapour pressure at + 50 °C 171 kPa. Maximum relative density 1.0. Maximum gross weight Not applicable. Other information or notes#

Page 588 08/25 11:38 S46 370 92222 : LEAR GNOSJÖPLAST # 002 BOREALIS ® REPORT File no.: 63.6310 EN 15001 RÉPORT Issued by an Accredited Laboratory Report no. MTU98020 Project no. 30042 TR по. 2195 Page 1 of 5 Number of enclose: 8 Manufacturer: Gnosjöplast AB Addreșs: S-33500 Gnosjö Test work is performed by: Attn.: SWEDEN Material Testing, Ø: (46) 370 33 15 50 Christer Lundh Borealis, Rønningen : • 8: (46) 37 09 22 22 Test specimen(s) arrival date: 30.01.96 Date of starting: 09.05.96 Date of completing: 14.01.98 - Title: UN TEST, 6 LITRE BLOW MOULDED PETROL CAN, WITH A 2,5 LITRE BLOW Distribution: MOULDED OIL CAN. (COMBINATION PACKAGING) External: 1. Christer Lundh Internal - 2. Runar Bjørsen 1. Inger Lise Stälhane 2. Helge Grande (first page) 4. Jens Dag Haivorsen (first page) 3. Hege Vale Baann (first page) 5. Secretary skill centre moulding Author/title: Date: Approved by head of lab. 1816-48 Date: Rune M. Fink / Engineer Inger dise Stälhane 18/6-98 Inger Lise Stålhane Tested items): Blow moulded 6 1 Petrol can (740 g), "CombiDunk 6+2,5*. Tests are ordered by: Jens Dag Haivorsen Date: 02.02.96 Material(s): Petrol can made of orange HMW HDPE HE 8253, MFR21s= 10.0, density = 0.853 Closure; screw cap with built in spout, made of green HMW HDPE HOSTAFORM S9244. Gasket and o-ring made of black rubber. Testing specification: The transport conventions ADR(by road), RID(by railway), IMDG(at sea). ICAO & IATA (by air) and UN recommendations on "Transport of dangerous goods", according to the latest revised edition. - Test goal: Approval for packing group II (including Il). Model liquid: White Spirit, specific gravity 1.0 Conclusion: The 6 litre Petrol can with one screw cap, 3H1, with a 2.5 litre blow moulded oil can (Combination packaging), fuffl the requirements for transport of dangerous special requirement for petrol cans. goods packing group II, ADR, latest revised edition. The can also pass the The test results relate only to the items tested. Maximum vapour pressure for the Petrol can at 50 °C is 171 KPa. Borealis AS The Register of Business Enterprises.NO 968144405 N-3960 Stathelle Telephone: +47 35 57 74 28 Telefax: +47 35 57 72 09#

Page 688 08/25 11:39 S46 370 82222 LEAR GNOSJÖPLAST @1003 INTRODUCTION I page 2 of 5 • • (petrol/oil in mixed packing). Gnosjöplast AB, Sweden have requested an accredited test for their 6 litre combi can It is no requirement regarding testing of the 2,5 litre oil can, but the drop test is performed with the oil can, pin mounted to the petrol can. This is done to take hold for the mass movement when the can hit the target. An accredited test for petrol cans includes; drop test leakproofness test (ADR 3552) internal pressure test (ADR 3554) (ADR 3553) stacking test permeation test (ADR 3555) (ADR 3556). The standard liquid used was White spirit at 1.0 sg. 1.1 Material specification Material in the Petrol can (and oil can): Orange HMW HDPE HE8253 (Enclosure 1). (Enclosure 2). Material in the screw cap with built in spout: Green HMW HDPE HOSTAFORM S9244 Material in the gasket and o-ring: Black rubber. (Enclosure 4, 5, 6 and 7). Design of the Petrol can, see photos (Enclosure 3) and drawing of the Petrol can Design of the screw cap, see photos (Enclosure 8). 1.2 Regulations/standards For all of the tests the methods are in accordance with the UN recommendations on TRID. specialy AR, de, revised el,and with the transport conventions The test procedure is made according to our interpretation of ADR, Appendix A.5. - - Borealis AS N-3960 Stathelle elephone: +47 35 57 74 2 The Register of Business Enterprises. NO 968141405 Tolefax: +47 35 57 72 09#

Page 7: '98 08/25 11:40 846 370 92222 LEAR GNOSJOPLAST 49004 I page 3 of5 1.3 Defined capacities, dimensions and weights. The Petrol can: Weight from producer (g): Weight average of 10 (g): 740 Nominal capacity (litre): 6.0 747.6 Brimful capacity (litre): 6.6 Measurements tw•d (on top) (mm): Minimum wall thickness (mm): 330•160•240 Max. gross weight (kg): 2,19 Max. tare mass (g): 10,0 1272 Inside diameter of the spout (mm): 39.4 The screw cap: Weight incl. gasket/spout (g): Outside height (mm): 125.0 Inside diameter (mm): 57.0 Weight of gasket (g): 45.0 2.3 The oil can: Weight include cap and screws (g) 407.0 • Formank A0 FalL.170E6771%#

Page 898 08/25 11:41 846 370 92222 LEAR GNOSJÖPLAST 49005 1 page 4 of 5 .2 TESTING PARAMETERS The Petrol can were tested for packing group IT with a closure torque at 3.0 Nm. The specific tests performed on the can was: 2.1 Chemical compatibility Performed with standard liquid; White Spirit. 22 Drop test The Petrol cans were filled up to 98% of Brimful capacity with a mixture of (1:1) of water and antifreeze, and cooled to -20 °C. The specific gravity of the antifreeze mixture is 1.07. Three cans were released to hit the target diagonally on the screw cap. Three cans were released to hit the target diagonally on the bottom seam. Note; the oil can containing glycol, was part of the drop test. Criteria for passing the test: No leakage shall occur. Provided the discharge is slight, and no further leakage occurs, it is not considered to be a failure of the test. 2.3 Leakproofness test Three empty Petrol cans were restrained just under the surface of water in a tank. An air minutes. pressure of 20 kPa was applied on each sample and remained constant for at least 5 Criteria for passing the test: No leakage shall occur. 24 Internal pressure test Three Petrol cans were filled with water, and a water pressure of 200 kPa was applied on each sample and remained constant or slightly above for at least 30 minutes. Criteria for passing the test: No leakage shall occur. 2.5 Stacking test The Petrol cans were filled up to minimum 98% of Brimful capacity with White Spirit (ADR 3551-1). The test sample should be subjected to a force applied to the top of the test sample equivalent to the total weight of identical packages in a height of 3 meters. The Petrol cans should be subjected to the stacking test for a period of 28 days, at a temperature of not less then 40 °C. (ADR 3555-3) Borealis AS N-3980 Stathette Telephone: +47 35 57 7428 The Register of Business Enterprises. NO 968141405 Telefax: +47 35 57 72 09#

Page 9'98 08/25 11:42 846 370 92222 LEAR GNOSJOPLAST 1Ø006 I page 5 of 5 • Criteria for passing the test: No leakage shall occur. The packaging shall not have been damage in such a way that it reduces the safety in transport, or have deformation that can reduce its strength. 2.6 Permeation test • • • The petrol cans were filled up to minimum 98% of Brimful capacity with White Spirit, measured after storage for 28 days at a temperature of 23° C. then immediately after, the weight of each can was measured. The weight was then • Criteria for passing the test: the permeation must not be higher than 8,0 mg/l/h. 3. RESULTS 3.1 White Spirit as standard liquid at sg 1.0. 3.1.1 Chemical compatibility than 40 °C, with standard liquid White Spirit. The chemical compatibility of the packaging is done by storage for 28 days at not less 3.1.2 Drop test, with drop height 1.2 m. • Three drops diagonally on the screw cap. Three samples approved. Three drops diagonally on the bottom seam. Three samples approved. 3.1.3 Leakproofness test, with air pressure of 20 kPa. : Three samples approved. 3.1.4 Internal pressure test, with hydraulic pressure of 200 kPa. Three samples approved. 3.1.5 Stacking test, with White Spirit at sy. of 1,0. Stacking weight 55 kg. Three samples approved. 3.1.6 Permeation test. The mean permeation of the three petrol cans were 0.9 mg//h, the limit is set to 8 mg/ih or less. Three samples approved. Borealis AS The Register of Business Enterprises. NO 968144405 N-3960 Stathelle Tolephone: +4735 57 7428 Telofax: +47 35 57 72 09#

Page 10•y8 U8/25 11:42 (3'40 J/U YZLZZ LLAK GNUSJUPLADI 18007 : Letter from Kenneth Nilsson, Mouldex Plast AB Enclosure 2 Telefax from : Mouldex Plast AB +46 44 24 58 39 Datum: 98-04-01 Jo: Lear Corporation, Christer Lundh • Faxno:0370-92222 CC: •From: Kvalitetsavdelningen / Kenneth Nilsson Pages: 1 Šubject - Bensinpip kpl (21004300100) Det.nr 4,22142 Den 3/12-97 levererade jag 10 st bensinpip med nytt material | skruvkorken och införd o-ring. • • Materialet i skruvkorken var : HOSTAFORM S9244 • • : Med vänlig hälsning - Kenneth Nilsson : • ! ostadress Totalon Mouldex Plast AB Fox S-291 09 Kristianstad Box 9093 + 46 44 24 64 00 +46 44 24 58 39 Sweden ! Lon. TØ GIS 6&85828 947 :2 B6 a 10#

Page 11'98 08/25 11:43 846 370 92222 LEAR GNOSJOPLAST 4008 Phats of the 6 litre petrol can Enclosure 3#

Page 12'98 08/25 11:46 046 370 92222 LEAR GNOSJOPLAST 44009 Dracking of the 6 lote can, and oil can from left Enclosure 4 100 6 = 5 30 2 LITE Te D •l'c ® Husqvarna MAX. 2,5: LITER: 230 10:0 Detalinr Benämning Matorial el. belackning Anmärkning#

Page 1398 08/25 11:47 46 370 92222 LEAR GNOSJOPLAST 49010 Drawing of the 6 lite car, and oil car from right Enclosure 5 BRANDFARLIGT NELAMMABLE BOEFZHALICH CEVAARLUK NDFARUGT NFAALIA FLAMABLE ENARKEA TE NFAMKABRE INFLAWVEL КОЛЕКТО arna 4029 anvandn ingser Minimivikt -730g: OLA 3HT/1/200/94/S/5693102 Made in Sweden BENSIN FUEL S 199403-28 5056930 Datum. Sign. stall ni Godk, for sorieprodi 2234 Färg: Orangers Foto Thi A2 Entiter, 1.3 Tinghti ning ne, Electrolux Motor Snik 505 6930#

Page 14'98 08/25 11:48 646| 370 82222 LEAR GNOSJOPLAST 44011 Drawing of the 6 litre car, and oil can from froat Enclosure 6 330 EUD 165 XxXX Tilverkninosor -50#

Page 15'98 08/25 11:50 846 370 82222* LEAR GNOSJÖPLAST 4012 Dracing of the 6 litre can, and oil can from bottom Enclosure 7 > PEL HE C 10 Li tillverkningsarer "j' 4= Do tră sisto siftrorno 160#

Page 16du vur bu Phats of the Screw cap •Exclosure 8 Cring pleced to make the can air- and liquidtig'*t#