Firetrace Systems International, Inc. — Hazardous Materials Safety Interpretation

Page 1of Transportation J.5. Department 400 Seventh Street. S.W Washington, D.C 20590 Research and Special Programs Administration MAY - 5 2000 .:.. Mr. Len Seebaluck, P.Eng. Ref. No. 99-0322 Engineering Manager Firetrace Systems International, Inc. 102, 118-Ist Avenue Cochrane, Alberta, Canada TOL OWO Dear Mr. Seebaluck: This is in response to your request for information on the requirements applicable to nonspecification cylinders that are used as fire extinguishers under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You described the aluminum cylinders as having volumetric capacities ranging from 70 cubic inches [1.15 L or 1,147.3 ml.] to 302 cubic inches [4.95 L], an operating pressure of 150 psi, and a minimum burst pressure of 900 psi. The cylinders will be imported into the United States from Canada. Your nonspecification fire extinguishers must fully meet the limited quantity requirements contained in § 173.309(a) through (a)(3)(iv). Your cylinders appear to meet the internal volume limitation and the minimum burst pressure requirements prescribed in paragraph (a)(3)(i) and (ii). As stated in paragraph (a)(3)(iii), prior to initial shipment, each cylinder must be tested, without evidence of failure or damage, to at least three times its charged pressured at 21 °C (70 °F). Each fire extinguisher must be marked with the test date and with the words "MEETS DOT REQUIREMENTS" The extinguishing agent must meet the requirements in Special Provision 18 in § 172.102. § 173.34(d)(2) . Shipments of the fire extinguishers must meet the shipping papers, packaging markings and, when offered for transportation by aircraft, the hazard warning labels requirements prescribed in Subparts C, D and E of Part 172, respectively. Shipments by air must also meet the per package 113.309 990322#

Page 2quantity limitations prescribed in the § 172.101 Hazardous Materials Table for the material and the general requirements in § 173.27. An electronic version of the HMR can be assessed through our internet web site at http://hazmat.dot.gov. I hope this information is helpful. Sincerely, Hotte 2. Mitchell Hattie L. Mitchell Chief, Regulatory Review and Reinvention Office of Hazardous Materials Standards 2#

Page 312/08/1999 14:58 9329999 FIRETRACE PAGE 01/02 • FIRETRACE' AUTOMATIC FIRE SUPPRESSION SYSTEMS karim Date: 8 December, 1999 8173.309 To: Mr. Edward Mazzullo 99-0322 Company: Director, Office of Hazardous Material Department of Transportation Fax: 202-366-3012 From: Len Seebaluck, P.Eng Engineering Manager Subject: D.O.T requirements for Shipping Charged Fire Extinguishing Cylinders Pages: Mr. Mazullo Firetrace Systems International Inc. is based in Canada and is in the Fire Protection business. Our intent is to ship our system, which contains pressurized cylinders, to the department of transportation, it would be much appreciated if you could provide me with U.S. Being unfamiliar with the regulations regarding shipping of cylinders under the guidance. According to 173.309 CFR, our cylinder is a nonspecification cylinder. Cylinder and system information Cylinder Material: Aluminum Cylinder Volume: Ranges from 70 in - 302 in? Operating Pressure: 150 psi Burst Pressure Min: 900 psi Cylinder listings: UL/ULC Extinguishing agents: Dry Chemical (ABC, BC) or FM-200 gas Questions: 1. What is the D.O. T requirement for shipping this cylinder to and within the U.S? 2. What is D.O.T labeling required? Does it need to be stamped on the cylinder or marked with a permanent ink? 3. Is any test required? If so, what is the procedure? • What type of packaging is required? 5. Is there a requirement for a pressure relief valve on this system? 6. What are the requirements if these charged cylinders are transported by air? 7. Are there any other considerations being overlooked? firetrace Systems international Inc. 102, 118 - Ist Avenus Cochrane, Alberia, Canada TOLOWO Tel: (403) 932-1218 Fax: (403) 932-9999 www.firetrace.com#

Page 412/08/1999 14:58 9329999 HIKE IKACE PHOE ULIUL We are hoping to soon begin one-year leak testing of our system with Underwriter's Laboratories, and prior to the start, I would appreciate if we could hear from you. Should you require any further information, do not hesitate to contact me. Thanking you in advance for you collaboration. bee#