HB Fuller Company — Hazardous Materials Safety Interpretation

Page 1U.S. Department 400 Seventh Street, S.W. of Transportation Washington, D.C. 20590 Special Programs Research and Administration SEP - 8 1999 HB Fuller Company Mr. Eugene J. Secor Ref. No. 99-0198 25200 Malvina Avenue Warren, MI. 48089 Dear Mr. Secor: This is in response to your letter dated July 13, 1999, and subsequent telephone conversation with a member of my staff, regarding the small quantity exception in § 173.4 of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) - Specifically you ask if your one piece molded plastic device consisting of two separate reservoirs would be considered two separate inner receptacles. Upon examination of your device it is the opinion of this Office that it is two separate receptacles that are attached. Provided each receptacle contains less than the quantities specified in § 173.4 for inner receptacles, you may qualify for the small quantity exception. I hope this satisfies your request. Sincerely, Office of Hazardous Materials Standards Iransportation Regulations Specialist 990198 13.22#

Page 2Products, Inc. H.B. Fuller Automotive BAH 31601 Research Park Drive 8173.22 Madison Heights, Michigan 48071 July 13, 1999 FAX (810) 585-3699 (810) 585-2200 • (800) 633-7789 99-0198 US DEPARTMENT OF TRANSPORTATION RSPA STANDARDS DEVELOPMENT, DHM-11 400 SEVENTH ST., SW WASHINGTON, DC 20590-0001 Re: Dual Discharge Syringe containing two different Hazardous Materials Gentlemen: which are hazardous materials for transportation purposes. Part A is classified as Our company makes a reactive adhesive system consisting of two parts, both of Amines, Liquid, Corrosive, nos, (Aliphatic Amine), 8, UN 2735, II and Part B is 2206, Il. classified as Isocyanate solution, Toxic, nos, (Hexamethylene diisocyanate), 6.1, UN Although Parts A & B can be sold and shipped in separate containers for use with large metering equipment; for prototype purposes it is preferred in duel syringes. This type syringe consists of two (2) tubes connected via a shut-off valve at the ottom (An example is enclosed). One tube would contain Part A whereas the othe ube would contain Part B. Discharge is 50% by volume of part A & B; Mixin occurs at discharge through the nozzle. Each filled syringe is inserted into a foil bag which is then sealed. This particular packaging combination does not appear to meet the definition of a chemical kit nor does it meet the definition of Polyester Kit. Since this package contains both of the aforementioned hazmats together; albeit separated in different tubes, how would one classify this package combination for shipment? Would this combination meet the small quantity exception in 173.4 presuming that it was packaged in nested, strong outer packagings, etc or would the Limited Quantity Exception be a more progressive choice? The Department's assistance is much appreciated on this particular query. An expeditious reply would be most helpful. I can be reached at 810-498-1317 during the day. 248 4783 BEST REGARDS, 526 Erogene A Decor HB FULLER COMPANY 25200 MALVINA AVE WARREN, MI 48089#