{"operation":"document","citation":"99-0044","title":"Fire Star Electric Match — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1999-05-14","effective_on":null,"summary":"99-0044 response to Fire Star Electric Match concerning 173.22.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-99-0044.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-99-0044.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-99-0044","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/1999/990044.pdf","body":"<<<PAGE 1>>>\n\n•\nof Transportation\nU.S. Department\nWashington, D.C.\n400 Seventh Street, S.W.\n20590\nResearch and\nSpecial Programs\nAdministration\nMAY | 4 1999\nMr. Jerry F. Dyben\nRef: No. 99-0044\nFire Star Electric Match\nPost Office Box 533\nNew Haven, IN 46774\nDear Mr. Dyben:\nThis is in response to your letter dated February 16, 1999, requesting clarification on the proper\nclassification and shipment of your rocket motor ignitor kit under the Hazardous Materials Regulations\n(HMR; 49 CFR Parts 171-180).\nUnder § 173.22 of the HMR, it is the shipper's responsibility to properly classify and describe a\nhazardous material. This Office generally does not perform this function. However, we provide\nassistance when we have the information available.\nBased on the information provided in your letter,\nyour rocket motor ignitor kit contains two products:\nBottle A\n6.1 grams of magnesium powder\n2.7 grams of titanium sponge powder\n8.8 grams of coating solution\nBottle B (High-density Polyethylene)\n17 grams of potassium perchlorate with vermiculite\nAccording to your letter and the HMR, magnesium powder is a Division 4.3 dangerous when wet\nmaterial, titanium sponge powder a Division 4.1 flammable solid material, and coating solution a Class 3\nflammable liquid. If your materials meet any of the hazard class defining critera in Part 173, they are\nsubject to the HMR.\nBased on the quantities of hazardous materials described in your rocket motor ignitor kit, and provided\nall provisions are met, your product may be shipped under the small quantities exception in § 173.4 of\nthe HMR. In order to ship as a consumer commodity, materials must meet the limited quantity\n990044\n11322\nimse\n\n<<<PAGE 2>>>\n\nprovisions for that hazard class in Part 173 and the definition of a consumer commodity in § 171.8 of\nthe HMR. Both Bottle A and Bottle B may be shipped within the same box, provided they are\ncompatible and will not react dangerously.\nI hope this answers your inquiry.\nSincerely,\nDil H6 Alo\nDelmer F. Billings\nChief, Standards Development\nOffice of Hazardous Materials Standards\n.. 500\n\n<<<PAGE 3>>>\n\nBoothe\nFireStar\n$173.22\nElectric\n99-0044\nMatch\n\"We're the Light of your Rocket Motor!\"\nOffice of Hazardous Materials Standards\nUS DOT RSPA\nDHM10 400 7th St. South West\nWashington, D.C.., 20590\nDear Mrs. Deborah Boothe,\nMy name is Jerry Dyben and i am President of FireStar Electric Match. My home business\nMatch sells a kit to the rocket community that allows the customers to make their own rocket\nsupports an inner-city ministry through Love church in For Wayne Indiana. FireStar Electric\ngrade glass bottle with a Teflon-lined green thermoset cap that provides a tight chemical-\nmotor ignitors. The kit contains two 1 oz Bottles marked bottle A & B. Bottle A is a laboratory\nresistant closure. Bottle B is a High-density polyethylene with threaded closure and with a vaive\nseal.\nFrom the 49 Code of Federal Regulations (49 CFR 173.4; ) Exceptions for Small Quantities\nthe small gram quantities that we are shipping that in case of fire would be of such insignificance\nRevised as of Oct. 1. 1994 that FireStar Electric Match used for shipping it's kits. It also contain\nthat it would add nothing to the total fire as shown below we are dealing in teaspoonfuls of\nhazardous material.\nBottle A contains the mixture of Flammable Solids and rubber elastomer with the following\nclassification in 49 CFR 172.101:\nBOTTLE A\nHAZARDOUS MAT. CLASS ID\nNo.\nPG\nLabels Required\nGrams\nMagnesium Powder --\n- 4.3\nUN 1418\nDanger when wet,\n6.1 grams\n•\nCombustible\nSpontaneously\nTitanium Sponge\nPowder -\n- 4.1\nUN 2878\nFlammable Solid\n2.7 grams\nCoating Solution-....\n• 3.0\nUN 1139\n#\nFlammable Liquid\n8.8 grams\nNow, at elevated temperatures both Titanium & Magnesium powders will burn in the atmosphere\nof both Nitrogen, Carbon Dioxide and Oxygen. However, both the Magnesium and Titanium\n\n<<<PAGE 4>>>\n\nprevents the moisture from reaching the Magnesium powder and thus No Spontaneous\npowders are now coated with a rubber elastomer. In the case of the Magnesium powder, it\nCombustion is possible. In a water test we performed one drop of the mixture from bottle A was\ngas was produced. in addition, no spontaneous combustion and after 3 days the test was\ndispensed into a pail of water. The drop formed on the surface in an irregular pattern and no\nended.\nSince the entire mixture is enclosed in a 1 oz. round laboratory grade glass jar with a Teflon-\nlined green thermoset cap that provides a very good air tight seal. This also insures a second\nbarrier to any moisture reaching the contents.\nIn a bonfire test we performed the thermoset cap on bottle A cracked allowing the gases to\nescape and the rubber vulcanized around the Flammable Solids so that when ignition\ntemperature was reached it went off like a fast burning sparkler There was NO explosion! V\nBottle B (High-density polyethylene) in that same bonfire test melted around the 17 grams of\nPotassium Perchlorate and the whole mass (Vermiculite included) was just one mass of carbon.\nAgain NO Explosion./\nDeborah, in a telephone conversation I had with Dr. W. Chang Bureau of Explosives on Nov. 15,\napproval because of such small quantity\".. I asked him if he would please put that in writing and\n1995 he stated, \"This is not an Explosive!, FireStar Electric Match does NOT need DOT\nhe refused stating that he did not want to become liable.\nIf that statement is not true then here are some questions need to know the answers to:\n1.\nDoes this product and the small quantites meet the definition of hazardous material? If\nso what special labeling, and/or packaging requirements would apply to this product so\nthat it could be legally shipment in the U.S.\n2.\nIf considered hazardous could this product be shipped as an ORM-D if it was to meet\nspecial packaging requirements and if so what special packaging would be required?\n3.\nDoes there exist any exemptions or party to exemptions that would allow regulatory relief\nfor this product and if so could you please list them?\n4.\nCan both Glass bottle A and Plastic bottle B be shipped within the same box. Both are\npackaged in vermiculite in the same plastic bag for shipment at this time.\nYour help in this matter will be deeply appreciated.\nThis package had been submitted to the following agencies and conforms to conditions and\nlimitations specified in 49 CFR 173.4: All the contents are under 30 mg.\nThe contents have been submitted to both:\nDr. W. Chang\nBureau of Explosives\nP.O. Box 415\nShort Hilles, NJ 07078\nUnder the Title, \"FireStar Electric Match Confidential\", In November 7, 1995 and was approved.\n\n<<<PAGE 5>>>\n\nThe above report was also sent to:\nDirector\nMaterials Transportation\nOffice of Hazardous Materials Regulation:\nResearch and Special Programs Administration\nU.S. Department of Transportation\nWashington, D.C., 20590\nAttn: Exemptions Branch\nI received my report back with an OK stamped on the title page. I have that report in my files.\n1 can be reached at Phone/Fax 1-219-749-9840.\nSincerely,\nTry 7. 4h\nJerry F. Dyben\nFireStar Electric Match\nP.O. Box 533\nNew Haven, IN 46774\nDOT_1.DOC\nPy :\n3414","truncated":false,"body_characters":7101}