We are writing to request your assistance in complying with the regulations. Your company is located in Miami, Florida, where the regulations are the same as in the Washington, D.C. metropolitan area. The rules of the United States Department of Transportation have been adopted in Florida as of 2003. These same laws and regulations govern shipments of aerosols. For clarification, we reproduce these regulations in its entirety for your information. “The hazard of fire from any product should be weighed against the hilariousness of its use. Aerosols should be considered as a hazardous material, and must be labeled accordingly.” “Flammable liquids used as packaging material. Aerosols should be considered hazardous, and not used in flammable liquids in such quantities as to pose a fire hazard.” 49 CFR 172.108 “Aerosols that contain more than 6.0 times the amount of a flammable liquid to be used in the aerosol and that have an initial flash point of not less than 101 °F (38 °C) should be labeled with the following statement to avoid a fire hazard: 'Aerosol Contains More Than 6.0 Times the Hazardous Quantity of Flammable Liquid' or 'Dangerous Flammable Liquid' (as appropriate) The hazard of fire from any product should be weighed against the hilariousness of its use. Aerosols should be considered as a hazardous material, and must be labeled accordingly.” 49 CFR 172.108 Under the International Maritime Dangerous Goods Code (IMG Code), aerosols that are shipped in accordance with the IMG Code, the same Hazardous Chemicals Regulations will apply as applicable elsewhere. Aerosols that are transported in flammable liquid containers or in aerosols, such as that which are contained in a can of aerosol spray, are not allowed to contain more than 6.0 times the weight of a flammable liquid. The maximum flammable liquid content for aerosol sprays should be based on the contents of the aerosol. If a product can be filled with more than 6.0 times the weight of the flammable liquid contained therein, the product should be labeled with such maximum flammable limit.” 49 CFR 173.
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U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Ave, S E Wash non DC 20590 JUL 2 3 2008 Mr. John Valencia Seaboard Marine Ltd. 8001 NW 79 Avenue
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