Willett Labeling Company — Hazardous Materials Safety Interpretation

Page 1~ of Transportation US.Department Washington, D.C. 400 Seventh Street, S.W. 20590 Special Programs Research and Administration JUN - 7 1999 Willett Labeling Company Ms. Alberta Millar Ref. No. 99-0078 6314-A Airport Freeway Fort Worth, TX 76117-5332 •":: Dear Ms. Millar: This is in response to your fax dated March 25, 1999, and subsequent telephone conversation with Eric Nelson of our staff regarding the classification of pressurized canisters of MEK based ink under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask for advice in classifying these canisters. Under § 173.22 of the HMR, it is the shipper's responsibility to properly classify a hazardous material. We are sorry that we can not further assist you in the classification of your product as the information provided to us in your fax and subsequent telephone conversation is inadequate. Generally, manufacturers have the knowledge to properly classify the materials and products they produce, although it may be necessary to enlist an outside laboratory to assist in the classification process, as testing may have to be conducted to see how a product compares to the criteria for various hazard classes. I hope this satisfies your request. Sincerely, orma I. All Thomas G. Allan Acting Director, Office of Hazardous Materials Standards 173.22 990078#

Page 203/25/1999 13:38 81(LLL205. 6314-A Airport Frwy. Willelt Fort Worth, TX 76117-5322 tel: (817) 222-2233 fax: (817) 222-0466 THE WORLD'S CODING AND LABELING COMPANY FACSIMILE MESSAGE No. Pages 1 Date: March 25, 1999 To: Hazardous Materials Regulations Information From: Alberta Millar - Consumables Product Manager Subject: Classification enquiry Please find to follow my question. I look forward to hearing from you soon. Kind regards Allillar. Alberta Millar#

Page 3For our new Willett printer we supply pressurised canisters that contain a small bag of MEK based ink. We are having problems with the classification of this product for transport by air. At the moment on the canisters we have the UN number for a flammable liquid and on the box carrying the canisters the UN number is for a flammable gas. The canisters are not aerosols as there is no nozzle on the top of the canister to atomize the ink and the pressurised air (Propellant) is not expelled with the product. The canister fits into a printer and the ink is not released into the atmosphere until the bag is collapsed by the compressed media around it, in turn feeding the ink to a system where it is printed via separate means. (in the form of large droplets which are formed by solenoid valves inside the printhead.) During can assembly, the bag inside the can is empty and the can itself is pressurised with air. During the filling, 297ml of MEK based ink is put into the bag, at this time the increase in the internal volume inside the can pressurises further the air inside the can. The initial pressure of the air is 54psi and the final pressure is 140psi.) Therefore, at this stage the canister cannot be classed as containing a flammable gas. The bag the ink is in is generally impermeable, however, we suspect that MEK vapours can actually diffuse through the bag, potentially allowing a mixture of MEK and air making a flammable mixture of gases. However, at some point, the level of MEK vapours inside the can will reach saturation point and will theréfore become non- flammable withour the addition of air. If the can is punctured, the MEK vapours would be released into the atmosphere, again at some point reaching the LEL associated with MEK, creating a flammable mixture of gases. Please could advise us on the correct classification for these canisters. "It can be noted that similar types of product are in the domestic market, such as shaving foams marketed by Gillette as shaving gel these products however use a flammable compressed charge to collapse the internal bag such as a Butane derivative. 173.308 what tup is 10 psi indicated? (130°8) Botze hot waiter berth test ASTM E Gil -85 167, 10s#