Fire Star Electric Match — Hazardous Materials Safety Interpretation

Page 1• of Transportation U.S. Department Washington, D.C. 400 Seventh Street, S.W. 20590 Research and Special Programs Administration MAY | 4 1999 Mr. Jerry F. Dyben Ref: No. 99-0044 Fire Star Electric Match Post Office Box 533 New Haven, IN 46774 Dear Mr. Dyben: This is in response to your letter dated February 16, 1999, requesting clarification on the proper classification and shipment of your rocket motor ignitor kit under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Under § 173.22 of the HMR, it is the shipper's responsibility to properly classify and describe a hazardous material. This Office generally does not perform this function. However, we provide assistance when we have the information available. Based on the information provided in your letter, your rocket motor ignitor kit contains two products: Bottle A 6.1 grams of magnesium powder 2.7 grams of titanium sponge powder 8.8 grams of coating solution Bottle B (High-density Polyethylene) 17 grams of potassium perchlorate with vermiculite According to your letter and the HMR, magnesium powder is a Division 4.3 dangerous when wet material, titanium sponge powder a Division 4.1 flammable solid material, and coating solution a Class 3 flammable liquid. If your materials meet any of the hazard class defining critera in Part 173, they are subject to the HMR. Based on the quantities of hazardous materials described in your rocket motor ignitor kit, and provided all provisions are met, your product may be shipped under the small quantities exception in § 173.4 of the HMR. In order to ship as a consumer commodity, materials must meet the limited quantity 990044 11322 imse#

Page 2provisions for that hazard class in Part 173 and the definition of a consumer commodity in § 171.8 of the HMR. Both Bottle A and Bottle B may be shipped within the same box, provided they are compatible and will not react dangerously. I hope this answers your inquiry. Sincerely, Dil H6 Alo Delmer F. Billings Chief, Standards Development Office of Hazardous Materials Standards .. 500#

Page 3Boothe FireStar $173.22 Electric 99-0044 Match "We're the Light of your Rocket Motor!" Office of Hazardous Materials Standards US DOT RSPA DHM10 400 7th St. South West Washington, D.C.., 20590 Dear Mrs. Deborah Boothe, My name is Jerry Dyben and i am President of FireStar Electric Match. My home business Match sells a kit to the rocket community that allows the customers to make their own rocket supports an inner-city ministry through Love church in For Wayne Indiana. FireStar Electric grade glass bottle with a Teflon-lined green thermoset cap that provides a tight chemical- motor ignitors. The kit contains two 1 oz Bottles marked bottle A & B. Bottle A is a laboratory resistant closure. Bottle B is a High-density polyethylene with threaded closure and with a vaive seal. From the 49 Code of Federal Regulations (49 CFR 173.4; ) Exceptions for Small Quantities the small gram quantities that we are shipping that in case of fire would be of such insignificance Revised as of Oct. 1. 1994 that FireStar Electric Match used for shipping it's kits. It also contain that it would add nothing to the total fire as shown below we are dealing in teaspoonfuls of hazardous material. Bottle A contains the mixture of Flammable Solids and rubber elastomer with the following classification in 49 CFR 172.101: BOTTLE A HAZARDOUS MAT. CLASS ID No. PG Labels Required Grams Magnesium Powder -- - 4.3 UN 1418 Danger when wet, 6.1 grams • Combustible Spontaneously Titanium Sponge Powder - - 4.1 UN 2878 Flammable Solid 2.7 grams Coating Solution-.... • 3.0 UN 1139 # Flammable Liquid 8.8 grams Now, at elevated temperatures both Titanium & Magnesium powders will burn in the atmosphere of both Nitrogen, Carbon Dioxide and Oxygen. However, both the Magnesium and Titanium#

Page 4prevents the moisture from reaching the Magnesium powder and thus No Spontaneous powders are now coated with a rubber elastomer. In the case of the Magnesium powder, it Combustion is possible. In a water test we performed one drop of the mixture from bottle A was gas was produced. in addition, no spontaneous combustion and after 3 days the test was dispensed into a pail of water. The drop formed on the surface in an irregular pattern and no ended. Since the entire mixture is enclosed in a 1 oz. round laboratory grade glass jar with a Teflon- lined green thermoset cap that provides a very good air tight seal. This also insures a second barrier to any moisture reaching the contents. In a bonfire test we performed the thermoset cap on bottle A cracked allowing the gases to escape and the rubber vulcanized around the Flammable Solids so that when ignition temperature was reached it went off like a fast burning sparkler There was NO explosion! V Bottle B (High-density polyethylene) in that same bonfire test melted around the 17 grams of Potassium Perchlorate and the whole mass (Vermiculite included) was just one mass of carbon. Again NO Explosion./ Deborah, in a telephone conversation I had with Dr. W. Chang Bureau of Explosives on Nov. 15, approval because of such small quantity".. I asked him if he would please put that in writing and 1995 he stated, "This is not an Explosive!, FireStar Electric Match does NOT need DOT he refused stating that he did not want to become liable. If that statement is not true then here are some questions need to know the answers to: 1. Does this product and the small quantites meet the definition of hazardous material? If so what special labeling, and/or packaging requirements would apply to this product so that it could be legally shipment in the U.S. 2. If considered hazardous could this product be shipped as an ORM-D if it was to meet special packaging requirements and if so what special packaging would be required? 3. Does there exist any exemptions or party to exemptions that would allow regulatory relief for this product and if so could you please list them? 4. Can both Glass bottle A and Plastic bottle B be shipped within the same box. Both are packaged in vermiculite in the same plastic bag for shipment at this time. Your help in this matter will be deeply appreciated. This package had been submitted to the following agencies and conforms to conditions and limitations specified in 49 CFR 173.4: All the contents are under 30 mg. The contents have been submitted to both: Dr. W. Chang Bureau of Explosives P.O. Box 415 Short Hilles, NJ 07078 Under the Title, "FireStar Electric Match Confidential", In November 7, 1995 and was approved.#

Page 5The above report was also sent to: Director Materials Transportation Office of Hazardous Materials Regulation: Research and Special Programs Administration U.S. Department of Transportation Washington, D.C., 20590 Attn: Exemptions Branch I received my report back with an OK stamped on the title page. I have that report in my files. 1 can be reached at Phone/Fax 1-219-749-9840. Sincerely, Try 7. 4h Jerry F. Dyben FireStar Electric Match P.O. Box 533 New Haven, IN 46774 DOT_1.DOC Py : 3414#