Olin Microelectronic Materials — Hazardous Materials Safety Interpretation

Page 1US Department + of Transportation Research and Administration Special Programs Advanced Projects Engineer Mr. James R. Mccoid MAY | 9 1995 223 15th Link Manufacturing, Street N.E. Ltd. P.O. Box 68 Sioux Center, IA 51250-0068 Dear Mr. Mccoid: i'ne Office of the Chief Counsel, National Highway Traffic your march 17, 1995 inquiry to Mr. Steve Woods. You ask about salety Administration (NHTSA), has forwarded to this office the applicability of the Hazardous Materials Regulations (HMR), suspension systems 49 C.I.R. Parts 171-180, to a damping device for truck cab 2500 to 3000 pounds per square inch. contains fluid at a static pressure of Programs Administration (RSPA) is the agency responsible for The Research and Special implementing the Federal hazardous material transportation law, 49 V.S.C. SS 5101-5127, and the HMR. The HMR apply only to hazardous material transported in motor vehicle solely as an integral part of the vehicle's motive Hazardous material that is being transported on a function is not being transported in commerce within the meaning of the HMR, and therefore is not subject to the HMR. of commerce, Transportation of the pressurized damping device as an article would be subject to the HMR. either by itself or assembled with other equipment, addresses hydraulic accumulators. Section 173.306 (f) Of the HMR Under conditions stated in paragraphs (f) (1) Or (f) (3) Of that section, transportation of the devices as articles of commerce would be excepted from some or all HMR requirements. This guidance concerns only the HMR. RSPA cannot address other Federal laws or regulations that may apply to the design or use of your device. I trust this response is helpful. If you have any questions, please feel free to call me at (202) 366-4400. Sincerely, charies Holtman Attorney CC: Ms. Dorothy Mr. Edward Mazzullo, RSPA/DHM-10 . Mazzana, RSPA/DHM 1/PCC-20#

Page 2= of Transportation U.S. Department 400 Seventh Street, S.W. Washington, D.C. 20590 special Programs Research and Administration JUN | 5 1998 Ms. Naomi Livingston Olin Microelectronic Materials P. O. Box 10099 Mesa, Arizona 85216-0099 Dear Ms. Livingston: This is in response to your letter regarding methods of achieving separation of hazardous materials, as indicated by the letter "O" in the Segregation and Separation Chart of Hazardous Materials (49 CFR 177.848(e)(3)), on the same transport vehicle in a manner that under conditions normally incident to transportation, commingling would not occur. This Office evaluates procedures used in complying with this requirement on a case-by-case basis. However, you did not provide any specific information on the hazardous materials involved or the methods your company may use to achieve separation. The requirement for separation or non-adjacent loading is considered satisfied if the packages are separated in such a manner (for example, by using barriers, packages of non-hazardous materials, or intervening space) that their contents would not commingle in the event of leakage under conditions normally incident to transportation. I hope this satisfies your request. Sincerely, Suhan ABillio Delmer F. Billings Chief, Standards Development Office of Hazardous Materials Standards#

Page 3En glum Tile: 177848(6)63) SC: 434, 414 MATERIAL: 1/15/98 Mr. Edward T. Mazzullo . Director, Office of Hazardous Materials Standards 400 7th Street S.W. U.S. DOT/RSPA (DHM-10) Washington, D.C. 20590-0001 Subject: 49 CFR Section 177.848 (e) (3) Dear Mr. Mazzullo: It is our understanding when shipping hazardous materials that require separation (indicated by letter "O" in the segregation table) together on the same transport vehicle, separation must be occur. achieved in a manner that under conditions normally incident to transportation, commingling would not What DOT recommendations can be made on methods of achieving separation? Your response is greatly appreciated. wingst Naori Livingston Olin Microelectronic Materials 6550 South Mountain Road P.O. Box 10099 Mesa, AZ 85242 Tel. (602) 987-7177 Fax. (602) 987-7087 Tel: 602-987-7000 • Fax: 602-987-7001 P.O. Box 10099, Mesa, Arizona 85216-0099#