Lockheed Martin — Hazardous Materials Safety Interpretation

Page 1= of Transportation U.S. Department 400 Seventh Street, S.W. Washington. D.C Research and Special Programs Administration APR 2 7 1998 MI. George Gaskill Lockheed Martin 199 Borton Landing Road Moorestown, NJ 08057-0927 Dear Mr. Gaskill: This is in response to your letter regarding the applicability of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) to manufactured articles containing limited quantities of hazardous material. You state that shipping names "Ethyl; ether, " UN1155, PG I and "Pentanes, " you are using the proper UN1265, PG I for transporting these manufactured articles request confirmation of your understanding of the limited and quantities provision ($ 173.150) specified for these entries in the exceptions column of the Hazardous Materials Table. You are correct in your understanding of the limited quantity exceptions for Class 3 (flammable liquids) as provided in $ 173.150. For Packing Group I materials, an inner packaging may not exceed • 1 gallon not exceed 66 pounds. Although the quantity of hazardous and the gross weight of the packaging may material in your manufactured articles is less than .1 gallon, the gross weight of each article is over 66 pounds. your manufactured articles do not meet the requirements for the Therefore, limited quantity exceptions in § 173.150. You may wish to contact the Research and Special Programs Administration's Office of Exemptions and Approvals. Exemptions certain requirements under the HMR. are granted on a case-by-case basis to authorize the relief of Procedures for applying for an exemption are set forth in § 107.105 of the HMR. The Office oI Exemptions and Approvals may be reached by telephone at (202) 366-4512. I hope this information is helpful. If we can be of further assistance, please do not hesitate to contact this office. Sincerely, FoR Hattiet. Mitchell, Chief Office of Hazardous Materials Standards Exemptions and Regulations Termination#

Page 2* JUN 26197 11:49AM PRODUCIBILITY ENG FoR EASSIaNMENT -ÜG .. FAX COVER SHEET LOCKHEED MARTIN A Lockheed Martin 199 Borton Landing Road Government Electronic Systems Product Integration Center Building 101-230 P.O. Box 1027 Moorestown, NJ 08057-0927 Fax No. (609) 722-3283 Mentire File: 173.150 NUMBER OF PAGES 385 (INCLUDING THIS SHEET) 2 SC: 114, DATE: June 26, 1997 TO: Department of Transportation tel. (800) 467-4922 FAX NO: (202) 366-8700 FROM: George Gaskill MAIL STOP: 101-230 EXTENSION: (609) 722-6077 COMMENTS: ATTENTION: Edward T. Mazzullo, Director of the Office of Hazardous Materials Standards A written response to a query on CFR 49 is requested See attached sheet for question details Could you please confirm receipt of this FAX? Dare If You Have Trouble With This Transmission, Call _ (609) 722-6077#

Page 3..and -is JUN 26 '97 11:49AM PRODUCIEILITY ENG P.2 A written response is requested for the following question on CFR 49 regarding the shipping of a component which contains hazardous materials. Q. Exception to regulations requirements for a finished article 1. We purchase manufactured assemblies containing a small quantity of flammable material. The material(s) are 2-Methyl butane or a mixture of Ethyl Ether and 2-Methyl butane. Section 173.150 exceptions are referenced in the 172.101 table of CFR 49. The table 172.101 shows Ethyl Ether on P.171 (UN1155) and 2- Pentane) and P.2230 (Downes 1) (UN 1265), boph me ters 1" are shown as Class III, group 1) 4. Ihe total quantity contained in the manutactured assembly (a temperature contro, valve) is less than 1 gallon. (Vrothgal lon 3. The manufactured article containing the small quantity weighs more than 66 Ibs. 4. Our understanding is that the weight of the article (valve) is the factor that incurs the regulatory requirements (performance packaging and labeling) in shipment, whereas it would otherwise be exempted if it weighed less (assuming the same quantity of hazardous material). 5. The regulations performance packaging adds considerable cost and complexity in shipping, both for our supplier and ourselves. Have we understood the requirements correctly? Can DOT explain the reasoning behind the requirements exemption for shipping devices with limited quantities of hazardous material, in particular the effect of the device weight on the exemption?#