Fireworks Mfg. Co Inc. — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department 400 Seventh Street, S.W. Washington, D.C. 20590 Special Programs Research and Administration MAY I 9 1999 Mr. Ronald C. Snyder Ref. No. 98-0340 Zambelli Internationale Fireworks Mfg. Co., Inc. Safety Office RD #1, Box 270A Edinburg, Pennsylvania 16116 Dear Mr. Snyder: This is in response to your letter requesting clarification on the use of orientation arrows on packages containing Division 1.3G explosives, Display fireworks, under the Hazardous Materials Regulations (HMR: 49 CFR Parts 171-180). I regret the delay in responding to your inquiry and hope it has not caused you any inconvenience. According to your letter, packages containing your Division 1 3G explosives materials are marked with orientation arrows indicating that they must be initiated with a certain side up. This kind of firework is initiated by laying the box in an upright position and lighting the fuse. As provided by § 172.312, orientation arrow markings are only required on packages containing liquid hazardous materials. I hope this answers your inquiry. Sincerely, Shan Hillio Delmer F. Billings Standards Development Office of Hazardous Materials Standards 980340 172.312#

Page 2Boothe 172.312 ZAMBELLI INTERNATIONALE 98-0340 FIREWORKS MFG. CO. INC. SAFETY OFFICE RD#1 BOX 270 A EDINBURG, PENNA. 16116 TELEPHONE NO. 1-800-797-6235 FAX # (724) 652-1456 DATE: 11-09-98 TO: ED MAZZULLO, DIRECTOR HMS FROM: RONALD C. SNYDER SUBJECT: QUESTION ON ORIENTATION ARROWS WE CARRY 1.3G EXPLOSIVES, DISPLAY FIREWORKS, WHICH DO NOT REQUIRE ORIENTATION ARROWS ON THE BOXES. HOWEVER SOME OF THE BOXES HAVE ARROWS ON THEM INDICATING THAT THEY MUST BE FIRED WITH A CERTAIN SIDE UP. THIS CERTAIN KIND OF FIREWORK IS FIRED BY LAYING THE BOX IN AN UP RIGHT POSITION AND LIGHTING THE FUSE. ALLA MAGAZINER FROM THE OHIO PUC IS DEMANDING THAT WE USE THESE ARROWS AS ORIENTATION ARROWS WHILE SHIPPING. WE WORK VERY HARD AT COMPLYING WITH ALL STATE AND FEDERAL REGULATIONS, BUT WE DO NOT WANT ANY ADDITIONAL BURDEN WE HAVE LOOKED ALL THROUGH THE REGULATIONS AND CAN'T FIND ANY REQUIREMENTS FOR THIS. THE ONLY REGULATIONS WE CAN FIND PERTAIN TO LIQUIDS, WHICH WE NEVER CARRY. CAN YOU PLEASE GIVE US YOUR OPINION ON THIS MATTER WE WILL ABIDE BY WHAT EVER YOU DECIDE.#