GARDERE ··._-'_ 

~!:ccRECEIVED attorneys and counselors • www.gardere.com 

Direct Dial: 713-276-5730 

Direct Fax: 713-276-6730 

Email: pmclaucblan@gardere.com 

,_ "'b p i; It'' { ~--. :: JUL 3 1 2013 

HEARING DOCKET 

July 30, 2013 

VIA UPS NEXT DAY AIR 

Federal Aviation Administration 

600 Independence Avenue, SW 

Wilbur Wright Building, Suite 2W1 000 

Washington, D.C. 20591 

Attention: Hearing Docket Clerk, AGC-430 

Re: FDMS No. FAA 2013-0286; 2011EA700202; In the Matter of Radio 

Holland USA, Inc.; U.S. Department of Transportation, Office of 

Hearings, Washington, D.C. 

Dear Sir or Madam: 

Please find enclosed the original and (1) one copy of Radio Holland USA, Inc.'s 

Response to Complainant's First Set of Interrogatories, Request for Production of 

Documents and Request for Admissions for filing in the above-referenced matter. I 

would appreciate you returning a date-stamped copy of the document to me in the 

enclosed self-addressed stamped envelope. · 

Thank you for your assistance in this matter. If you have any questions or 

concerns, please do not hesitate to contact me. 

PAM:seb 

Enclosure 

dMdlllRIOW~!l:.tl&vElL LLP 

Very truly yours, 

~d-A<~ 

Peter A. McLauchlan 

1000 Louisiana, Suite 3400, Houston, Texas 77002-5011 • 713.276.5500 Phone • 713.276.5555 Fax 

Austin • Dallas • Houston • Mexico City 

-... -
. . .. 

U.S. DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

OFFICE OF HEARINGS 

WASHINGTON, D.C. 

In the Matter of Radio Holland USA, Inc. 

2011EA700202 

FDMS No. FAA-2013'-0286 · 

Richard C. Goodwin, 

U.S. Administrative Law Judge 

RECEIVED 

JUL 3 1 2013 

HEARING DOCKET 

RADIO HOLLAND USA, INC.'S RESPONSE TO COMPLAINANT'S FIRST SET OF 

INTERROGATORIES, REQUEST FOR PRODUCTION OF DOCUMENTS 

AND REQUEST FOR ADMISSIONS 

Pursuant to 14 C.F.R. 13.220 and Rules 33, 34 and Rule 36 of the Federal Rules of Civil 

----·- -·------------- --···-·---- -··~·--·----

Procedure, Radio Holland USA, Inc. ("RH") responds to Complainant's First Set of 

Interrogatories, Request for Production of Documents and Request for Admissions. 

GardereOl • 6338027v.l 

Respectfully submitted, 

GARDERE WYNNE SEWELL L~ /.a_ 

By: ~d-Ae~~ 

Peter A. McLauchlan 

Texas Bar No. 13740900 

Anacarolina Estaba 

Texas Bar No. 24085298 

1000 Louisiana Street, Suite 3400 

Houston, Texas 77002 

Telephone: 713.276.5370 

Facsimile: 713.276.6370 

Email: pmclauchlan@gardere.com 

Email: aestaba@gardere.com 

ATTORNEYS FOR RESPONDENT, 

RADIO HOLLAND USA, INC. 

1 
CERTIFICATE OF SERVICE 

I, Peter A. McLauchlan, do hereby certify that true and correct copy of the foregoing 

instrument was served upon the following parties as indicated below on this 30th day of July, 

2013: 

VIA UPS NEXT DAY DELIVERY 

Jeanine C. Gotimer 

Attorney at Law 

Federal Aviation Administration 

1 Aviation Plaza. 

Jamaica, NY 11434 

VIA UPS NEXT DAY DELIVERY 

The Honorable Richard C. Goodwin 

Administrative Law Judge 

Office of Hearings, M-20 

U.S. Department of Transportation 

1200 New Jersey Avenue, S.E. (E11-310) 

Washington, D.C. 20590 

VIA UPS NEXT DAY DELIVERY 

· ··Federal Aviation Administration (Original and one copy) 

600 Independence Avenue, S.W. 

Washington, D.C. 20591 

Attn: Hearing Docket Clerk, AGC-430 

Wilbur Wright Building -Suite 2W1000 

GardereOl - 6338027v.l 

2 

Jf'Ld.}t~ Peter A. McLauchlan 
GENERAL OBJECTIONS TO DISCOVERY REQUESTS 

1. Discovery is ongoing in this action. As such, RH reserves the right to supplement its 

responses to these requests. 

2. RH objects to these requests to the extent that they require it to marshal its available 

proof or the proof it intends to offer at trial in violation of the Federal Rules of Civil 

Procedure and the attorney work product doctrine. The responses given below are based 

upon facts currently known and information currently available to RH. 

3. Rfl objects generally to requests propounded by Co!Ilplainant to the extent that they 

purport to impose a different or greater burden on RH in responding than is allowed or · 

required by the Federal Rules of Civil Procedure. To the extent that RH is required to 

respond to these requests, it is only required by the Federal Rules of Civil Procedure to 

search for and produce responsive documents within its possession, custody, and control. 

~ will produce all relevant, non-privileged documents currently in its possession, 

custc)dy, and control as they are kept in. the _usu'!.l_course of business consistent with 

Federal Rules of Civil Procedure. To the extent that these requests seek to impose a 

greater burden in searching for responsive documents contained in those documents or 

contained in Complainant's own documents, RH objects on the ground that the requests 

for production are unduly burdensome. 

4-. - RH objects to the produGtion of infonnati911 that is within Complainant's possession or 

control or that is more readily accessible to ComPJainant or fhal are publicly-available. -

5. RH objects to any presumption, pursuant to Federal Rules of Civil Procedure, that any 

document it produces that was not prepared or created by it, but is a document received 

from some other entity and maintained in its files, is authenticating. To the extent that 

any document produced by RH that was prepared or created by some other person or 

entity, RH has no way of knowing if such document is authentic and reserves the right to 

contest such document's authenticity at trial. 

6. RH objects to any definition, instruction, or request that seeks to require it to produce or 

identify documents that are in the care, custody, or control of a third-party or that are 

already in Complainant's possession. Any such definition, instruction, or request is 

overly broad and unduly burdensome. 

7. RH objects to any request to the extent such request violates the attorney-client privilege, 

attorney work product doctrine, or joint defense privilege. 

3 

GardereOl- 6338027v.l 
ANSWERS TO INTERROGATORIES 

INTERROGATORY NO.1: 

Identify the names, titles, business or home addresses and telephone numbers of each person 

whom the Respondent intends to call as a witness at the hearing of this matter. 

ANSWER: 

Damon Cole 

Service Engineer 

10416 New Berlin #8 

Jacksonville, FL 32226 

Tel.:(904) 571-6705 

Subject to and without waiving the General Objections, discovery is ongoing and RH reserves 

its right to supplement this interrogatory. 

INTERROGATORY NO.2: 

Provide the substance of the testimony to be offered by each of said witnesses. 

ANSWER: 

Damon Cole will provide testimony related to his practice, training and knowledge of releasing 

and emptying butane contained in soldering irons before boarding a passenger carrying flight. 

INTERROGATORY NO.3: 

With respect to each expert witnyss identified in response to request Nos. 1 and 2 above: 

(a) identify the subject matter on which the expert is expected to testify; 

(b) list the substance of the facts and opinions to which the expert is expected to 

testify; 

(c) provide a summary of the grounds for each opinion; 

(d) If the Respondent intends to introduce into evidence or otherwise rely upon a 

written curriculum vitae or other written document listing the expert's 

professional qualifications, identify and attach copies of all such documents. 

ANSWER: 

Subject to and without waiving the General Objections, discovery is ongoing and RH reserves 

its right to supplement this interrogatory. 

4 

GardereO 1 - 6338027v.l 
INTERROGATORY NO.4: 

To the extent not encompassed in your response to request Nos. 1, 2 and 3 above, identify and 

produce statements of all individuals who spoke to, or were interviewed by, the Respondent 

regarding this matter. 

ANSWER: 

RH objects to this request as vague, overbroad, ambiguous, compound and multifarious. 

Subject to and without waiving the General Objections and the foregoing objections, after a 

·due diligent search, RH has not identified any documents responsive toJhis in~yrrogatory._ 

INTERROGATORY NO.5: 

Identify and produce copies of any and all documents on which the Respondent anticipates 

relying, or will rely, in support of the case it will present at the hearing in this matter, including 

but not limited to documents you intend to introduce into evidence. 

ANSWER: 

RH objects to this request as vague, overbroad, ambiguous, compound and multifarious. Subject 

to and without waiving the General Objections and the foregoing objections, RH will rely on 

documents produced by the.fM, Ag~nt Louis Fernandez's deposition, and any other documents 

necessary to support its defense. Discovery .is ongoing-and RHreserves its right· to suppl~ment 

this interrogatory. 

INTERROGATORY NO.6: 

Set forth and describe each incident where Mr. Cole had a soldering iron confiscated while 

traveling on behalf of Respondent. 

ANSWER: 

Prior to or following this incident, Mr. Cole has had some soldering irons confiscated while 

traveling. 

INTERROGATORY NO.7: 

Identify each and every company policy that exists for employees traveling with tools, including 

soldering irons. 

ANSWER: 

RH has a policy to field personnel and personnel in service and projects directing field service 

personnel regarding carrying ofbutane soldering irons on flights. 

5 

GardereO l - 6338027v.l 
INTERROGATORY NO.8: 

Describe in full detail the Department of Transportation Hazardous Materials Regulations (DOT 

HMR) general awareness/ familiarization training provided to Respondent's employee Damon 

Cole, including the name and address of the person who provided training to Mr. Cole, the date 

the training was given, and the substance of the training given. 

ANSWER: 

RH provides a training course on DOT HMR general awareness/familiarization, including 

subjects reiating to Safety (both generat··and area specific)-, Personal Development _and __ 

Customer Service, which are provided through Mastery Technologies, Inc. 

INTERROGATORY NO.9: 

Describe in full detail the DOT HMR function-specific training provided to Respondent's 

employee Damon Cole including the name and address of the person who provided training to 

Mr. Cole, the date the training was given, and the substance of the training given. 

ANSWER: 

Training is provided by Mastery Technologies, Inc. 

INTERROGATORY NO. 10: 

State the factual basis for Respondent's belief that Mr. Cole received general awareness/ 

familiarization training pursuant to 49 CFR 172.702(c) prior to March 4, 2011. 

ANSWER: 

Mr. Cole received general awareness/ familiarization training through Mastery Technologies, 

Inc. 

6 

GardereO 1 - 6338027v.l 
RESPONSE TO FIRST REQUEST FOR PRODUCTION OF DOCUMENTS 

REQUEST FOR PRODUCTION NO. 1: 

Produce copies of all materials relied upon and/or consulted in responding to the Agency's First 

Set of Interrogatories and First Requests for Admissions. 

RESPONSE: 

RH objects to this request as vague and overbroad. Subject to and without waiving the General 

Objections and the foregoing objections, seeRH000001-RH000042. 

REQUEST FOR PRODUCTION NO.2: 

Provide copies of each and every company policy that exists for employees traveling with tools 

including soldering irons. 

RESPONSE: 

Subject to and without waiving the General Objections, see RH000027-RH000030. 

REQUEST FOR PRODUCTION NO.3: 

Produce copies of any- statements from ·any person whom Respondent or its representative. 

interviewed in connection with the instant matter. 

RESPONSE: 

Subject to and without waiving the General Objections, after a due diligent search, RH has not 

identified any documents responsive to this request. RH reserves the right to supplement this 

request. 

REQUEST FOR PRODUCTION NO. 4: 

Produce copies of any notes from interviews of any person Respondent or its representative 

interviewed in connection with the instant matter. 

RESPONSE: 

Subject to and without waiving the General Objections, after a due diligent search, RH has not 

identified any documents responsive to this request. RH reserves the right to supplement this 

request. 

REQUEST FOR PRODUCTION NO. 5: 

Produce copies of all documents upon which Respondent intends to rely at the hearing on this 

matter. 

RESPONSE: 

7 

GardereO 1 - 6338027v.l 
RH objects to this request as vague, overbroad, and ambiguous. Subject to and without waiving 

the General Objections and the foregoing objections, please refer to answer to Interrogatory No. 

5 herein. 

REQUEST FOR PRODUCTION NO.6: 

Produce a copy of each certification showing that Mr. Cole was trained and tested in general 

awareness/ familiarization training as required by the DOT HMR at 49 CFR §172.704 (a)(l). 

RESPONSE: 

Subject to and without waiving the General Objections and the -foregoing objections, see -

RHOOOOOl-26 and RH000031-42. 

REQUEST FOR PRODUCTION NO.7: 

Produce a copy of the training materials used to train Damon Cole in DOT HMR general 

awareness/ familiarization training. 

RESPONSE: 

Subject to and without waiving the General Objections and the foregoing objections, see 

RHOD0001-26_~nd RH000031-42. 

REQUEST FOR PRODUCTION NO.8: 

Produce a copy of each certification showing that Mr. Cole was trained and tested in hazardous 

material training in accordance with the requirements prescribed in Subpart H of the DOT HMR. 

RESPONSE: 

Subject to and without waiving the General Objections, after a due diligent search, RH has not 

identified any documents responsive to this request. RH reserves the right to supplement this 

request. 

REQUEST FOR PRODUCTION NO.9: 

Produce a copy of the training materials used to train Damon Cole in hazardous materials 

training in accordance with the requirements prescribed in Subpart H of the DOT HMR. 

RESPONSE: 

Subject to and without waiving the General Objections, after a due diligent search, RH has not 

identified any documents responsive to this request. RH reserves the right to supplement this 

request. 

8 

GardereO 1 - 6338027v.l 
REQUEST FOR PRODUCTION NO. 10: 

Produce a copy of all testing materials used to test Damon Cole in DOT HMR general 

awareness/ familiarization training. 

RESPONSE: 

Subject to and without waiving the General Objections and the foregoing objections, see 

RHOOOOOl-26 and RH000031-42. 

REQUEST FOR PRODUCTION NO. 11: 

Produce a copy of all testing materials used to test Damon Cole in DOT HMR function-specific 

training. 

RESPONSE: 

Subject to and without waiving the General Objections and the foregoing objections, see 

RHOOOOOl-26 and RH000031-42. 

9 

GardereOI- 6338027v.l 
RESPONSE TO REQUEST FOR ADMISSIONS 

REQUEST FOR ADMISSION NO. 1: 

On or about March 4, 2011, Damon Cole travelled on behalf of Respondent aboard US Airways 

Flight 4084 from Norfolk, VA to Philadelphia, PA. 

RESPONSE: 

Admit. 

REQUEST FOR ADMISSION NO. 2: 

Damon Cole offered an Ultra Torch soldering iron in his checked baggage for transportation 

aboard US Airways Flight 4084 from Norfolk, VA to Philadelphia, PA on or about a March 4, 

2011. 

RESPONSE: 

Admit. 

REQUEST FOR ADMISSION NO. 3: 

-Tiie tJlfni Torch solderihg-iron-Mr: Cole used,-in-or aboutMarch20ll, in the_ pe-r:f<?rmance of his 

duties for Respondent used butane fuel. - . . - ··· --

RESPONSE: 

Admit. 

REQUEST FOR ADMISSION NO. 4: 

The Material Safety Data Sheet (MSDS) Respondent provided to Complainant on April 7, 2011 

is accurate. 

RESPONSE: 

Admit. 

REQUEST FOR ADMISSION NO. 5: 

The Material Safety Data Sheet (MSDS) Respondent provided to Complainant on April 7, 2011 

describes the proper shipping name of butane fuel as Petroleum gases, liquefied. 

RESPONSE: 

Admit. 

10 

GardereO 1 - 6338027v.l 
REQUEST FOR ADMISSION NO. 6: 

The Material Safety Data Sheet (MSDS) Respondent provided to Complainant on April 7, 2011 

describes the Class and Division Number ofbutane fuel2.1 (Flammable Gas). 

RESPONSE: 

Admit. 

REQUEST FOR ADMISSION NO.7: 

- -- --- .. 

The Material Safety Data Sheet (MSDS) Respondent provided to Complainant on April 1: 2011 

describes the UN Number ofbutane fuel as UN-1075. 

RESPONSE: 

Admit. 

REQUEST FOR ADMISSION NO. 8: 

The Material Safety Data Sheet (MSDS) Respondent provided to Complainant on April 7, 2011 

describes the required labels for butane gas as Flammable Gas label on each non-bulk package. 

- RESPONSE:-

Admit. 

REQUEST FOR ADMISSION NO.9: 

Butane fuel is regulated by the Department of Transportation Hazardous Materials Regulations, 

49 CFR 171 et. seq. (DOT HMR). 

RESPONSE: 

Admit. 

REQUEST FOR ADMISSION NO. 10: 

The proper shipping name of butane fuel is Petroleum gases, liquefied. 

RESPONSE: 

Admit. 

REQUEST FOR ADMISSION NO. 11: 

Petroleum gases, liquefied is in Hazard Class 2.1 and has an assigned identification number of 

UN 1075. 

11 

GardereO 1 - 6338027v.l 
RESPONSE: 

Admit. 

REQUEST FOR ADMISSION NO. 12: 

The proper label for Petroleum gases, liquefied is FLAMMABLE GAS. 

RESPONSE: 

Admit. 

REQUEST FOR ADMISSION NO. 13: 

Petroleum gases, liquefied are hazardous materials forbidden for transportation aboard a 

passenger carrying flight. 

RESPONSE: 

Deny. 

REQUEST FOR ADMISSION NO. 14: 

- --Mt-:- Cole ·offered the Ultra--Torch- soldering -iron for trans_p_o:(t~t!on ~board US Airways Flight 

4084 from Norfolk, VA to Philadelphia, PA on or about a March 4, 2011 in a -non-bulk package. 

RESPONSE: 

Admit. 

REQUEST FOR ADMISSION NO. 15: 

Mr. Cole offered the Ultra Torch soldering iron for transportation aboard US Airways Flight 

4084 from Norfolk, VA to Philadelphia, PA on or about a March 4, 2011 in a non-bulk package 

when he failed to ensure it was purged of Petroleum gases. 

RESPONSE: 

Deny. 

REQUEST FOR ADMISSION NO. 16: 

At all times referred to in the complaint, Damon Cole was employed by Respondent. 

RESPONSE: 

Admit. 

12 

Gardere01-6338027v.l 
REQUEST FOR ADMISSION NO. 17: 

Damon Cole is employed by Respondent as a service engineer and has been so employed since 

August 2008. 

RESPONSE: 

Admit. 

REQUEST FOR ADMISSION NO. 18: 

Damon Cole in the course of his employment with Respondent uses commercial air 

transportation in the United States. 

RESPONSE: 

Admit. 

REQUEST FOR ADMISSION NO. 19: 

On or about March 4, 2011 Damon Cole was traveling with his necessary tools including the 

Ultra Torch UT-lOOSI soldering iron, on behalf of Respondent. 

- --

RESPONSE: 

Admit. 

REQUEST FOR ADMISSION NO. 20: 

On or about March 4, 2011, Damon Cole knew that butane was a regulated hazardous material. 

RESPONSE: 

Admit. 

REQUEST FOR ADMISSION NO. 21: 

While used during the course of Cole's employment with Respondent, the Ultra Torch soldering 

iron contained butane fuel. 

RESPONSE: 

Deny. 

REQUEST FOR ADMISSION NO. 22 

The Ultra Torch soldering iron makes a hissing sound when turned on and button is depressed if 

it contains butane fuel in the reservoir. 

13 

GardereO! - 6338027v.l 
RESPONSE: 

Deny. 

REQUEST FOR ADMISSION NO. 23: 

Damon Cole has previously had soldering Irons confiscated while traveling on behalf of 

Respondent. 

RESPONSE: 

Admit. 

REQUEST FOR ADMISSION NO. 24: 

On or about March 4, 2011, Damon Cole boarded US Airways Flight 4084 from Norfolk, 

Virginia to Philadelphia, Pennsylvania on behalf of Respondent during the course of his 

employment. 

RESPONSE: 

Admit. 

REQUEST FOR ADMISSION NO. 25: 

On or about March 4, 2011, Damon Cole offered in his checked baggage an Ultra Torch 

soldering iron for air transportation aboard US Airways Flight 4084, a passenger carrying flight 

from Norfolk, Virginia to Philadelphia, Pennsylvania with onward travel to Jacksonville, Florida. 

RESPONSE: 

Admit. 

REQUEST FOR ADMISSION NO. 26: 

Mr. Cole's checked baggage for US Airways Flight 4084 was not accompanied by a Shipper's 

Certification or Declaration of Dangerous Goods at any time on or about March 4, 2011. 

RESPONSE: 

Admit. 

REQUEST FOR ADMISSION NO. 27: 

Mr. Cole's checked baggage for US Airways Flight 4084 on or about March 4, 2011 did not bear 

a Flammable Gas label. 

14 

GardereO I - 6338027v.l 
RESPONSE: 

Admit. 

REQUEST FOR ADMISSION NO. 28: 

Respondent's employees, including Damon Cole, were not instructed to label their tools for air 

travel prior to March 4, 2011. 

RESPONSE: 

Deny. 

REQUEST FOR ADMISSION NO. 29: 

Mr. Cole's checked baggage for US Airways Flight 4084 on or about March 4, 2011 was not 

marked with the proper shipping name and identification number for the butane fuel that is used 

in the Ultra Torch soldering iron. 

RESPONSE: 

Deny. 

REQUEST FOR ADMISSION NO. 30: 

Mr. Cole's checked baggage for US Airways Flight 4084 on or about March 4, 2011 did not bear 

a CARGO AIRCRAFT ONLY label. 

RESPONSE: 

Admit. 

REQUEST FOR ADMISSION NO. 31: 

On or about March 4, 2011 when Damon Cole, travelling on behalf of respondent, offered the 

Ultra Torch in his checked baggage for US Airways Flight 4084, no shipping papers 

accompanied the checked baggage. 

RESPONSE: 

Admit. 

15 

GardereO I - 6338027v. I 
000 Radio 000 . 000 . 

Radio Holland USA Inc. 

8943 GulfFreeway 

Houston, TX 77017 

RE: 2011EA700202 

---· 

Mr. Carlos Garcia 

Federal Aviation Administration 

Lead Investigator 

PO Box 861528 

Warrenton, VA 20 187-1528 

· Dear Mr. Garcia, 

Date: April?, 2011 

I am writing this letter in response to case 2011EA700202 regarding the alleged violation of Title 49 Code 

of Federal regulations (49 CR). In relation to the transportation of hazardous materials in air commerce, I 

have attached the following infommtion and present the detail below as per request of Mr. Earl Andreasen, 

Manager, WDC Security Field Office and to yourself, lead investigator for the FAA. 

The "Ultra torch model UT-IOOSI'' is a tool that we regularly use on a daily basis within our working 

environment and we, Radio Holland USA Inc., do understand this type of instnunent is not allowed in air 

commerce without proper identification and classification as Hazcom materials. In light ofthis, Radio 

Holland-USA lnc;-is-banning-all-Butane-Soldering-irons (all models) fi'opt o_!!r J!ir travels. yve_~a~e_ 

alternatives that will be implemented as follows: 

1) Electric soldering irons will be replaced when the need for air travel is required. 

2) Obtain Butane unit via local source at destination if applicable to the job demand. 

Copies of the MSDS are attached for your review and have been distributed throughout our field service 

organization and administrative staff. 

Our warehouse managers in our 6 regions have obtained Hazcom training through Federal Express 

ICAO/IATA, dangerous goods shipper's seminar. Although this measure is in place, it is not enough for 

us. Radio Holland USA Inc. is assembling a HAZCOM training course that will have proof of compliance 

for all of our field technicians. Our Houston based Warehouse and Logistics Coordinator, Daniel Charest 

will assemble a training program and begin the training process in Q3 this year and expect to have all 

trained by calendar year end for 2011. Daniel's final exam (included in this packet) is an example of the 

testing we will complete with each field technician. 

To prevent any future incidents, we have banned any Butane related tooling to be authorized for air 

commerce as mentioned above in the alternative measures. 

I hope this infonnation is adequate for you in the investigation and do look forward in hearing back from 

you on this matter. Please do not hesitate to call me with any further questions or detail that you may 

require. 

RH000001 
U.S. Depat1menL_ 

ofTmnsportntioll 

Federal Aviation 

Administration 

WDC Security Field Office 

Security ond Hazardous Malerials Safety __ 

PO Box 861528 

Warrenton, VA 20187-1528 

CERTIFIED MAIL- RETURN RECEIPT REQUESTED 

Date: MAR 1 7··2011 

Mr. Bl'iau Kraut 

Radio Holland USA Inc. 

240 Tolley Rand Ave 

Jacksonville, FL 32202 

RB: 2011EA700202 

Dear Mr. Kraut: 

Personnel of this office are investigating the circumstances sm"l'OUilding alleged violations of Title 49 

Code of Federal regulations (49 CFR), pet1aining to the transportation of hazardous materials in ail' 

commerce. Specifically, the Federal Aviation Administration (FAA) is investigating an allegation 

that on March 4, 2011, an employee ofRadio.Holland USA Inc. (RHI) located at 240 Talley Rand 

Ave in Jacksonville, FL, offered an undeclnred hatardous material shipment fot' air transportation. 

The shipment was tendered fot· transport on US Airways flight 4084 destined to Philadelphia, P A 

with onward tl'avel to Jacksonville, FL. The Transportation Security Administration (TSA) 

discovered this shitltnent during oroutine out bound inspection of checked baggage. Specifically, the 

product offe1·ed for shipment was an "Ultm torch model UT-lOOSl', soldering iron containing butane 

fuel, which is classified as: UN 1075, Petroleum Gases Liquefied, Class 2.1. This product is 

FoJ'bi<ltlen on pnssenge1· bearing aircraft. 

The FAA is investigating whethet' an employee ofRHI who prepared and offered this shipment is 

properly trained. Preliminary infonnation indicates that RHI employee, Damon Cole was the person 

who prepared and offered the shipment to US Airways at Norfolk International Airport, Norfolk, Va. 

This lettet' is to inform you that the mattet' is under investigation by the FAA. You are encouraged to 

provide a statement in response to this incident. Yo\lr statement should include a detailed account of 

both the extenuating and mitigating ch·cumstances that resulted It\ this incident, which you feel have 

a bearing on this investigation. As a part of our investigation the FAA requests that you fum ish the 

following infonnation: 

• A copy of a Matel'ial Safety Data Sheet (MSDS) fo1· the product, which indicates the 

material's appropriate hazard classification when offered for transportation in commerce; 

• Copies of hazal'dous matel'ials trailililg records, in accordance with 49 CFR 172, Subpart H, 

RH000002 
which indicate that each employee involved with the preparation andlot· offering of hazardous 

materials in conunerce has received proper training; and 

• An explanation of the corrective actions implemented to prevent similar incidents from 

occurring in the future. 

As pmt of out· investigation, the FAA must detennine whether RHl is a small business concern under 

__ applicable law. To assist us in making this determination, please provide your company's North 

An1edcanhidushy Clnssificntiou-Systcm code{NAICS), and total numb_etofcurrent employees ot· 

annual receipts for the most recently completed fiscnl year. lnfonnation about the Smalll3\1siiless 

Administration's size standards and method of calculation determinations (either number of 

employees or amlUalreceipts) can be found at www.sbu.gov/size. 

Any discussion or wl'itten statements furnished by you will be given considemtion in om· 

investigation. If we do not hear from you within the specified time, our report will be processed 

without the benefit of your statement. Send your \VI'itten statement to the address referenced above. 

Sincerely, 

·· -~ Mnnagel·,-WDC Security Field Office 

RH000003 
Material Safety Data Sheet 

May be used to comply with 

U.S. Department of labor 

OSHA's Hazard Communication Standard, 

29 CFR 1910.1200. Standard must be 

consulted for specific requirements. 

Occupational Safety and Health Administration 

(Non-Mandatory Form) 

Form Approved 

OMB No. 1218-0072 

Page 1 of2 

IDENTITY (As used on !abel and list) 

Master Appliance Ultratane Butane Fuel 

Note: Blank spaces are not permitted. If any item is not applicable, or no 

Information Is available, the space must be marked to indicate that. 

.. SECTION I. 

MANUFACTURER'S NAME Master Appliance Corp. EMERGENCY TELEPHONE NO. 1-800-535-5053 (lnfotrac) 

ADDRESS 2420 18TH Street 

POBOX68 

RACINE WI 53401 

TELEPHONE NO. FOR INFORMATION 1-262-633-7791 

DATE PREPARED 

SIGNATURE OF PREPARER 

SECTION II. HAZARDOUS INGREDIENTS/IDENTITY INFORMATION 

HAZARDOUS COMPONENTS 

January 6, 2011 

(optional) 

(Specific Chemical Identity: Common Name(s)) 

lsobutane (CAS 75-28-5) 

OSHA PEL 

NE 

1000ppm 

800ppm 

ACGIH TLV Other Limits Recommended% (optional) 

sooppm 

Propane (CAS 74-98-6) NE 

Butane (CAS 106-97-8) SOOppm 

SECTION Ill. SHIPPING INFORMATION 

PROPER SHIPPING NAME 

CLASS AND DIVISION NUMBER 

UN NUMBER 

REQUIRED LABELS 

PACKING GROUP 

Petroleum Gases, Liquefied 

2.1 (Flammable Gas) 

UN-1075 

Flammable Gas label on each non-bulk package 

Not Listed 

SECTION IV. PHYSICAUCHEMICAL CHARACTERISTICS 

BOILING POINT 11°F 

30±2 

SPECIFIC GRAVITY (H20 = 1) .571 

1 

Negligible 

MELTING POINT -138c 

EVAPORATION RATE (Butyl Acetate= 1) 1 

VAPOR PRESSURE @70°F (psig) 

VAPOR DENSITY (air= 1) 

SOLUBILITY IN WATER 

APPEARANCE AND ODOR Clear gas with fight ethereal odor 

SECTION V. FIRE AND EXPLOSION HAZARD DATA 

FLAMMABLE LIMITS 

FLASH POINT (METHOD USED) · 

EXTINGUISHING MEDIA 

SPECIAL FIRE FIGHTING PROCEDURES 

LEL: 1.4 UEL: 9.5 

-100"F Estimated 

Dry chemical, foam, carbon dioxide 

Use water spray to cool containers. Avoid rocketing containers. 

UNUSUAL FIRE AND EXPLOSION HAZARDS Containers generate pressure when heated causing violent bursting and 

dangerous propelling of containers. 

RH000004 
Material Safety Data Sheet For Master Appliance Ultratane Butane Fuel 

January 6, 2011 Page 2 of 2 

SECTION VI. REACTIVITY DATA 

STABILITY 

CONDITIONS TO AVOID 

Stable: Yes Unstable: 

Not established 

INCOMPATIBILITY (Materials to Avoid) Oxygen and strong oxidizing materials 

HAZARDOUS DECOMPOSITION OR BYPRO DUCTS Carbon oxides formed when burned 

HAZARDOUS POLYMERIZATION .. May occur: Will not occur: Yes 

CONDITIONS TO AVOID Not established 

SECTION VII. HEALTH HAZARD DATA 

ROUTE(S) OF ENTRY Inhalation? Yes (A) Skin? Yes (B) Ingestion? N/A 

HEALTH HAZARDS (Acute and Chronic) (A)Simple asphyxiant, dizziness, disorientation, headache, excitation, central 

nervous system depression, anesthesia. 

(B) liquid contact with exposed skin can cause frostbite. 

CARCINOGENICITY? N/A NTP? N/A IARC MONOGRAPHS? N/A OSHA REGULATED? N/A 

SIGNS AND SYMPTOMS OF EXPOSURE Dizziness, headache, ect. 

MEDICAL CONDITIONS GENERALLY AGGRAVATED BY EXPOSURE None 

EMERGENCY AND FIRST AID PROCEDURES Remove from exposure. If irritation develops seek medical attention. 

SECTION VIII. PRECAUTIONS FOR SAFE HANDLING AND USE 

STEPS TO BE TAKEN IN CASE MATERIAL IS RELEASED OR SPILLED Protect from ignition. Ventilate area 

thoroughly. 

WASTE DISPOSAL METHOD Treatment, storage, transportation and disposal must be in accordance with applicable 

Federal, State and Local regulations. 

PRECAUTIONS TO BE TAKEN IN HANDLING AND STORING Store below 120•F. In case of accidental puncturing with 

forklift, shut off forklift and any other possible source of 

Ignition. Ventilate area. 

OTHER PRECAUTIONS Use with adequate ventilation. 

SECTION IX. CONTROL MEASURES 

RESPIRATORY PROTECTION (Specific Type) 

VENTILATION 

LOCAL EXHAUST 

MECHANICAL (General) 

PROTECTIVE GLOVES 

EYE PROTECTION 

OTHER PROTECTIVE CLOTHING OR EQUIPMENT 

WORKIHYGiEN.iC PRATICES 

N/A 

Adequate 

For small enclosed work areas 

Adequate for storage 

Not required for normal handling 

Safety Glasses 

Not required for normal handling 

N/A 

SECTION X. NFPA HAZARD CODES- HMIS RATING 

HEALTH: 1 FIRE: 4 REACTIVITY: 0 

RHOOOOOS 
MATERIAL SAFETY DATA SHEET 

1 CHEMICAL PRODUCT & COMPANY IDENTIFICATION 

TRADE NAME 

CAS NUMBER 

MSDS NUMBER 

PRODUCT CODE 

SYNONYMS. 

SUPPLIER 

PROPANE 

74-98-6 

5399 

ND 

.LPG 

HD-5 PROPANE 

LIQUEFIED PETROLEUM GAS 

C3 

P-GRADE 

Capital City Oil 

911 SE Adams 

Topeka, KS 66601 

TELEPHONE NUMBERS (800) 211-8008 

2 COMPOSITION /INFORMATION ON INGREDIENTS 

[lng~edient Name 

F---r--·· 

~~~ber . jConcentration* ~osure Limits I 

lth Hazards - . - . . 

. 

/PROPANE . - ·- F-F-- 1000 ppm 8-Ho_IJ_r -----__ ' 

8-6 92 -1oo% - ·rryvA (OSHA) . • . S1mple Asphyxiant 

· (ACGirr) . 

!ETHANE F4_;·-/o _ 7-%-- Simple Aspf1yxiant 0 

. (ACGIH) 

~I~OBUTAN-E FB-5-r _ 2.5% 800 ppm 8-Hour 

jTWA (OSHA) I 800 ppm 8-Hour 

tfWA (ACGIH) 

IN-BUTANE 1106-97-8 /o-1% ~00 ppm 8-Hour ---

WA(ACGIH) /ISOPENTANE 178-78-4 lo- o.5% /ND 

L-66-0 l_ 0.5 % 

j1000 ppm 8-Hour 

~WA{OSHA) 

PENTANE 1 ro ppm 8-Hour 

WA(ACGIH) 

so ppm 15-Min 

STEL (ACGIH) 

ETHYL MERCAPTAN Fl r·5 ppm 8-Hour TWA (USED ASA r- 50 ppm 

MAL ODORANT) (Trace) (ACGIH) . . . . . . 

/PROPYLENE 1115-07-1 10-500 ppm Simple Asphyxiant (Trace) (ACGIH} 

=-· 

RHOOOOO& 
" Values do not reflect absolute minimums and maximums; these values are 

typical which may vary from time to time. 

ND =No Data 

NA = Not Applicable 

3 HAZARDS IDENTIFICATION 

EMERGENCYOVERWEW 

HEALTH HAZARDS 

DANGER! 

MAY CAUSE CARDIAC SENSITIZATION 

ASPHYXIANT GAS 

OVEREXPOSURE MAY CAUSE CNS DEPRESSION 

LIQUEFIED MATERIAL MAY CAUSE FROSTBITE AND FREEZE BURNS 

FLAMMABILITY HAZARDS 

EXTREMELY FLAMMABLE 

FORMS EXPLOSIVE MIXTURES WITH AIR 

MAY CAUSE FLASH FIRE 

REACTIVITY' RAZJfRDS 

STABLE 

POTENTIAL HEALTH EFFECTS, SKIN 

Contact with liquefied material may cause frostbite. Short term contact 

may result in tissue destruction and severe burns. 

POTENTIAL HEALTH EFFECTS, EYE 

Direct contact with liquefied material may cause frostbite and permanent damage. 

POTENTIAL HEALTH EFFECTS, INHALATION 

Asphyxiant gas. High concentrations in the immediate area can displace 

oxygen and can cause central nervous system depression from oxygen 

deprivation. Symptoms may include headache, excitation, euphoria, 

dizziness, incoordination, drowsiness, iight-headedness, blurred vision, 

fatigue, tremors, convulsions, loss of consciousness, coma, respiratory 

arrest and death, depending on the concentration and duration of exposure. 

May cause cardiac sensitization, including arrhythmias (irregular heart 

beats) and death due to cardiac arrest. 

Overexposure to this material may cause systemic damage including 

target organ effects listed under "Special Toxic Effects." 

Other specific symptoms of exposure are listed under "Special Toxic 

RH000007 
Effects." 

POTENTIAL HEALTH EFFECTS, INGESTION 

Not a normal route of exposure. 

SPECIAL TOXIC EFFECTS 

Acute or chronic overexposure to this material or its components may 

cause systemic toxicity, including adverse effects to the following: 

cardiovascular and central nervous systems. 

Contains asphyxiant which may cause reproductive and/or developmental 

effects in pregnant women. 

Pre-existing medical conditions which may be aggravated by exposure 

include disorders of the respiratory and cardiovascular systems. 

4 FIRST AID MEASURES 

SKIN For frostbite or freeze burns, keep affected area warm by 

immersing or flushing with warm water. GET IMMEDIATE 

MEDICAL ATTENTION. 

EYE Burns due to either hot or cold contact require immediate 

medical attention. Flush immediately with large amounts 

of water for_ atJ~c:t§U!? roin_u_tes.. Ey_elids should be-held 

a-waifrom the eyeball to ensure thorough rinsing. GET 

IMMEDIATE MEDICAL ATTENTION. 

INHALATION Remove to fresh air. If not breathing, institute 

cardiopulmonary resuscitation (CPR). If breathing is 

difficult, ensure airway is clear and give oxygen. Keep 

affected person warm and at rest GET IMMEDIATE 

MEDICAL ATTENTION. 

INGESTION Keep affected person warm and at rest. GET 

IMMEDIATE MEDICAL ATTENTION. 

NOTES TO In cases of acute poisoning, artificial respiration with 

PHYSICIAN administration of oxygen may be useful for support. DO 

NOT GIVE EPINEPHRINE, EPHEDRINE OR SIMILAR 

ADRENERGIC DRUGS. THEY MAY INDUCE FATAL 

VENTRICULAR FIBRILLATION. Electrocardiographic 

monitoring should be carried out with severely ill patients 

to anticipate possible cardiac arrest. 

5 FIRE FIGHTING MEASURES 

HAZARDOUS COMBUSTION PRODUCTS 

Combustion may produce COx, NOx, SOx, reactive hydrocarbons and 

irritating vapors. 

EXTINGUISHING MEDIA 

RH000008 
Use water spray, dry chemical, alcohol foam, all purpose AFFF or 

carbon dioxide to extinguish fire. 

BASIC FIRE FIGHTING PROCEDURES 

Shut off source of flow if possible. Do not attempt to extinguish fire if gas 

source cannot be shut off first. 

Evacuate area and fight fire from a safe distance. 

If leak or spill has not ignited, ventilate area and use water spray to 

disperse gas or vapor and to protect personnel attempting to stop a leak. 

Use water spray to cool adjacent structures and to protect personnel. 

Containers can build up pressure if exposed to heat (fire). Stay away 

from storage tank ends. Withdraw immediately in case of rising sound 

from venting safety device or any discoloration of storage tank due to 

fire. 

Be aware that a BLEVE (Boiling Liquid Expanding Vapor Explosion) may 

occur unless surfaces are kept cool with water. 

Firefighters must wear MSHA/NIOSH approved positive pressure 

breathi!lg_ app~ratus (.SCBA) with full-face mask and full protective equiPment. 

UNUSUAL FIRE & EXPLOSION HAZARDS 

Extremely flammable. Vapors form flammable or explosive mixtures with 

air at room temperature. Vapor or gas may spread to distant ignition 

sources and flash back. 

Explosion hazard if exposed to extreme heat or to physical'or thermal 

shock. 

Fires involving this product may release COx, NOx, SOx, reactive 

hydrocarbons and irritating vapors. 

Flash Point-156 F (-104 C) 

Autolgnition Temperature 842 F (450 C) 

Flammability limits in Air, lower, % by Volume 2 % 

Flammability limits in Air, Upper, % by Volume g 5 % 

6 ACCIDENTAL RELEASE MEASURES 

EMERGENCY ACTION 

Eliminate and/or shut off ignition sources and keep ignition sources out 

of the area. Keep unnecessary people 

away; isolate hazard area and deny entry. Stay upwind. Isolate for 1/2 

mile in all directions if tank, rail car or 

tank truck is involved in release. Evacuate area endangered by release 

RH000009 
as required. (See Personal Protection 

Information Section.) 

ENVIRONMENTAL PRECAUTIONS 

Eliminate all sources of ignition. Isolate hazard area and deny entry. 

If product is released to the environment, take immediate steps to stop 

and contain reiease. Caution should be exercised regarding personnel 

.. safety. and exposure to the released product. Notify local authorities and -

the National Response Center, if required. 

SPILL OR LEAK PROCEDURE 

Keep ignition sources out of area and shut off all ignition sources. Isolate 

spill area and keep unnecessary people away. Use water spray to 

reduce vapors. Stop leak when safe to do so. 

See Exposure Controls/Personal Protection (Section 8). 

7 HANDLING & STORAGE 

HANDLING 

Ground lines and equipment used during transfer to reduce the 

possibility of static ·spark:initiated fire or explosion. Use non-sparking 

tools. Do not cut, grind, drill, weld or reuse containers unless adequate 

precautions are taken against these hazards. 

Do not eat, drink or smoke in areas of use or storage. 

STORAGE 

Store in tightly closed containers in a cool, dry, isolated, well-ventilated 

area away from heat, sources of ignition and incompatibles. Avoid 

contact with strong oxidizers. 

Empty containers may contain product residue. Do not reuse without 

adequate precautions. 

Do not eat, drink or smoke in areas of use or storage. 

8 EXPOSURE CONTROLS I PERSONAL PROTECTION 

ENGINEERING CONTROLS 

Ventilation and other forms of engineering controls are the preferred 

means for controlling exposures. 

EYE PROTECTION: PERSONAL PROTECTION EQUIPMENT (PPE) 

Wear safety glasses with side shields. A means for quick drenching or 

flushing of the eyes should be provided for first aid purposes. 

RH000010 
SKIN PROTECTION: PERSONAL PROTECTION EQUIPMENT (PPE) 

Avoid skin contact with this material. Use appropriate chemical protective gloves when handling. 

Use good personal hygiene. 

RESPIRATORY PROTECTION: PERSONAL PROTECTION 

EQUIPMENT (PPE) 

A NiOSH/MSHA approved air purifying respirator with an organic vapor 

cartridge or canister may be permissible under certain circumstances 

where airborne concentrations are expected to exceed exposure limits. 

Protection provided by air purifying respirators is limited. Use a positive 

pressure air supplied respirator if there is any potential for an 

uncontrolled release, exposure levels are not known, or any other 

circumstances where air purifying respirators may not provide adequate protection. · 

9 PHYSICAL & CHEMICAL PROPERTIES 

ODOR AND APPEARANCE 

COLORLESS, ODORLESS LIQUID UNDER PRESSURE WITH 

MALODORAN1_AD[)ED 

COLORLESS, ODORLESS GAS AT ROOM TEMPERATURE AND PRESSURE 

Boiling Point 

Specific Gravity 

Melting Point 

Percent Volatile 

Vapor Pressure 

Vapor Density 

Bulk Density 

Solubility in Water 

Octanoi/Water 

Partn 

Volatile Organic 

Pour Point 

pH Value 

Freezing Point 

Viscosity 

Evaporation Rate 

Molecular 

-44 F {-42 C) 

0.49-0.508 

-310 F (-190 C) 

100 

175-208 psi AT 100 F (38 C) 

1.5 (AIR= 1) 

NO 

SLIGHTLY SOLUBLE 

ND 

ND 

ND 

ND 

ND 

NO 

LIQUID BOILS RAPIDLY TO GAS AT ROOM 

TEMPERATURE 

C3H8 

RH000011 
Formula 

Molecular Weight 

Chemical Family 

Odor Threshold 

44.0900 

ALIPHATIC HYDROCARBON 

NO 

10 STABILITY & REACTIVITY 

STABILITY/INCOMPATABILITYIncompatible with oxidizing agents. See precautions under Handling & Storage (Section 7). 

HAZARDOUS REACTIONS/DECOMPOSITION PRODUCTS 

Combustion may produce COx, NOx, SOx, reactive hydrocarbons and irritating vapors. 

11 TOXICOLOGICAL INFORMATION 

TOXICOLOGICAL DATA 

See Special Toxic Effects (Section 3). 

12 ECOLOGICAL INFORMATIONECOTOXICOLOGICAL INFORMATION 

NO 

13 DISPOSAL CONSIDERA TJONS 

WASTE DISPOSAL 

This product, as supplied, when discarded or disposed of, is a hazardous 

waste according to Federal Regulations (40 CFR 261) due to its 

ignitability. Under the Resource Conservation and Recovery Act (RCRA), 

it is the responsibility of the user of the product to determine, at the time 

of disposal, whether the material is a hazardous waste subject to RCRA. 

The transportation, storage, treatment and disposal of RCRA waste 

material must be conducted in compliance with 40 CFR 262, 263, 264, 

268 and 270. Disposal can occur only in properly permitted facilities. 

Check state and local regulations for any additional requirements as 

these may be more restrictive than federai laws and regulations. 

Chemical additions, processing or otherwise altering this material may 

make the waste management information presented in this MSDS 

incomplete, inaccurate or otherwise inappropriate. Disposal of this 

material must be conducted in compliance with all federal, state and local regulations. 

14 TRANSPORT INFORMATION 

BILL OF LADING - BULK (U. S. DOT) 
Petroleum Gas, Liquefied, 2.1, UN 1075 

U. S. Department of Transportation (DOT) Requirements 

General Transportation Information for Bulk Shipments 

Proper Shipping 

Name Petroleum Gas, 

liquefied 

Ha:zard Class 2.1 UNINACode 

Packaging Group UN1075 NA 

labels Required Flammable Gas 

Placards Required Flammable Gas, 

UN1075 

Reportable Quantity See Regulatory 

Information 

{Section 15) 

General Transportation Information for Non-Bulk Shipments 

Proper Shipping 

Name 

-

Hazard Class 

Packaging Group 

labels Required 

Placards Required 

Petroleum Gas, 

Liquefied 

2.1 

NA 

Flammable Gas 

Flammable Gas, 

UN1075 

Reportable Quantity See Regulatory 

Information 

{Section 15) 

15 REGULATORY INFORMATION 

FEDERAL REGULA TlONS 

UNINACode 

UN1075 

All known major components of this product are listed on the TSCA 

Inventory and/or are otherwise in compliance with TSCA. 

A release of this product, as supplied, is exempt from reporting under the 

Comprehensive Environmental Response Compensation and liability 

Act (CERCLA) by the petroleum exclusion. Releases may be reportable 

to the National Response Center (800-424-8802) under the Clean Water 

Act, 33 U.S.C. 1321 (b)(3) and {5). Failure to report may result in 

substantial civil and criminal penalties. Check state and local regulations 

for any additional requirements as these may be more restrictive than federal laws and regulations. 

.! 

RHOO(l013 
This product does not contain toxic chemicais (in excess of the 

applicable de minimis concentration) that are subject to the annual toxic 

chemical release reporting requirements of the Superfund Amendments 

and Reauthorization Act (SARA) Section 313 (40 CFR 372). 

This product contains one or more substances listed as hazardous, toxic 

or flammable air pollutants under Section 112 of the Clean Air Act. This 

product contains substances subject to accident prevention regulations 

when present above the threshold quantities of 10,000 pounds (section 

"112(rtofthe Clean Air Act). This product contains up to 100% volatila· 

organic compour.ds (VOCs) per 40 CFR Part 51.100. 

There may be specific regulations at the local, regional or state/provincial 

level that pertain to this product. 

STATE REGULATIONS 

Based on available information this product does not contain any 

components or chemicals currently known to the State of California to 

cause cancer, birth defects or reproductive harm at levels which would 

be subject to Proposition 65. Reformulation, use or processing of this 

product may affect its composition and require re-evaluation. 

;!S~R,A _ _TIThE I!! ~TI~G~_ ··-· __ __ ]n .. ·jllmmediate rv·jDelayed lvjFire (;!Pressure D 

' !Hazard j" !Hazard f_!Hazard _ rJHaz§lrd _ r rl~=~~;~ity ~~r--···--···-----------------, 

INFPA_RATINGS 

niHealth riFiammability 

IIi IV!!~ ~ T~G~ 

r!Health -W!Fta~ma-bility 

16 OTHER INFORMATION 

MISCELLANEOUS 

This product has been malodorized to facilitate its identifiability. It has 

been determined that the odorant can diminish or fade due to exposure 

to oxidized substances, including the following: 

1. Adsorption ("sticking") of the odorant molecules to the inside surface 

of metal storage containers and pipes, particularly (i) those that are new; 

(ii) those whose interior surfaces have been exposed to the atmosphere 

while out of service; or (iii) those whose interior surfaces are rough. 

2. The presence of ordinary red rust (iron or ferric oxide) inside a storage 

container or piping. 

3. Selective absorption ("filtering") of the odorant molecules by soil in the 

case of underground leaks. 

RH000014 
4. Absorption of the odorant molecules on the walls (particularly those 

made of rough woods, rock or any other types of masonry) or on the 

fabric of draperies, furniture or carpets in rooms where there is little or no 

air circulation. 

Physical and environmental conditions such as competing odors, 

common colds, allergies, or smoking may lessen a person's ability to 

smell the odorant. In addition, prolonged exposure to the odorant or 

~xposure to extremely high concentrations of the odorant can diminish a 

person's ability to smell the odorant Finally, some individuals ar.e not 

capable of smelling the odor emitted by the odorant. 

All product users and handlers should ac.quaint themselves with what 

they determine to be the usual odor of odorized product. Further, as 

such individuals use or handle the product, proper precautions should be 

taken to ensure that the exposure of the product to substances such as 

those identified above is eliminated or to properly passivate such 

substances prior to use. Frequent sniff tests should be conducted. 

Handlers and retailers of the product should conduct periodic stain tube 

or other testing to ensure proper levels of the odorant are maintained 

and documented. Special attention should be focused on storage or 

transportation systems which exhibit the characteristics described above. 

In the event a lower level of odorant than required by law is discovered 

pursuant to the stain tube or other..testing, a.dditipnal odorant, or 

additional, properly odorized propane, should be added:- --

Purchaser and all downstream individuals who engage in the re-selling 

of product should continually communicate, inform, and train their 

employees, customers, and the public at large regarding the 

characteristics and hazards of the product, including specifically the 

possible failure of the odorant warning system under certain 

circumstances. 

DISCLAIMER 

NOTICE: The information presented herein is based on data considered 

to be accurate as of the date of preparation of this Material Safety Data 

Sheet. However, MSDS may not be used as a commercial specification 

sheet of manufacturer or seller, and no warranty or representation, 

expressed or implied, is made as to the accuracy or comprehensiveness 

of the foregoing data and safety information, nor is any authorization 

given or implied to practice any patented invention without a license.·ln 

addition, no responsibility can be assumed by vendor for any damage or 

injury resulting from abnormal use, from any failure to adhere to 

recommended practices, or from any hazards inherent in the nature of 

the product 

RH000015 
~edEx Express 

ICAO/IATA 

_ Oangerous _Goods Shipper's_ ~efl"lin~r Finai.Te~t -

January 2010 

Name: \)0.. '1\ "'-'L\ 0 Jn(>,,tU-o + ~-

Date: __ 1_-+-} -=-·2_(__;,_\-l-(___:,·?::.----;:,_ll_i ..;:,.0 _______ _ 

I 

Company Name: 

Instructor Name: 

RH000016 
Final Test Dangerous Goods Shipper Seminar 

Test Information 

This is an open-book test. You may use the lATA Manual, FedEx Express Dangerous Goods Seminar Participant 

Manual, or any other references presente.d in class to complete the test. 

Directions: 

I. Complete the info~ation on the top -of the AI!s\ver Slieet. · 

2. Read each question carefully from the Final Exam. 

3. Answer all the questions on the Answer Sheet and the simulated package and Shipper's Declaration page. 

4. Questions I - 15 are multiple choice. Select the correct answer and completely fill in the appropriate circle. 

A .!;i .C. D.. Each question is worth 3 points. 

0 0 • 0 

5. The Test Case 

There are 5 questions to answer - Each question is worth I point. 

Correctly mark and label the package using the peel off labels in the back of your participant manual. The 

markings and labels are worth a total of 16 points. ··· 

Complete the Shipper's Declaratipn. It is wo1ih a total of34 points. 

· 6. The instructor will tell you when to tum in your test for grading. 

7. lATA considers a score of 80 to satisfactmily pass the course. FAA considers a score of 70 to be passing in 

"other" types of testing. However it is up to your employer to determine what be/she feels is satisfactory. 

8. If you have any questions during the test please ask the instructor. 

January 2010 2 

RH000017 
~~ Dangerous Goods Shipper Seminar 

~ 

1. US Government (US G) Variation 12 regulates which of the following? 

~ Emergency phone numbers 

B. Radioactive Material 

C. Cylinders 

D. Airbags 

Final Test 

2. Using Packing Instruction 305 for an Ethanol Solution what is the maximum quantity that can be shipped 

in an IP2 plastic inner packaging? 

G SL 

B. lOL 

C. lOKG 

D. 25L 

3. What packing instruction number must be used, wl1en shipping two (2) gallons of UN 1987 in one 

package, if it has a Hash point of-58° F ~and a boiling point of 260° F? ¥L 'P6 II_ 

A. Packing Instruction 808 

B. Packing Instmction 309 

@ Packing Instruction 307 

D. Packing Instruction 305 

4. When shipping UN 1558 with FedEx there is a FedEx variation that applies to this hazard. What does the 

FedEx variation require? 

A. Metal drum as an outer package 

B. FedEx does not accept UN 1558 

C. A maximum quantity of 30 ml in the package 

(Q) DOT Special Permit packaging and/or "V" rated packaging 

January 2010 

3 

RH000018 
Final Test Dangerous Goods Shipper Seminar ~a,~ ~~ 

5. Compressed gas cylinders must be constructed and closed to prevent any loss of contents, how must valves 

be protected from damage? 

A. Packaging must consist of an aluminum pressure vessel. 

B. 

C. 

• The _work0g p~essure must not exceed 75% of the test pressure of the cylinder. 

The gas must be contained in a hem1etically sealed glass or ~etal ~~er packaging. - · 

® The cylinders must be fitted with valve protection caps, shrouds/guards or securely packed in strong outer 

packaging. 

6. What packing group would apply for UN 3267 if the MSDS reflects an Exposure time of 66 minutes and an 

Observation time of 7 days? 

A. Packing Group I 

B. Packing Group TI 

(§) Packing Group Til 

D. Not regulated as a corrosive material 

7. What is the most important step in preparing and packaging any battery or battery powered equipment 

for transport? 

A. To ship them in fire proof metal boxes. 

B. To ship them only by ground transportation. 

C. To remove all acid or alkali from the battery. 

@ To prevent short circuit by effective insulation of exposed tem1inals and unintentional activation. 

8. When shipping an Excepted Quantity (EQ) of UN 2861, what is the maximum quantity allowed in each 

inner packaging? 

G9 1 gil mi 

B. 30 g/30 ml 

C. Skg 

D. No limit 

January 2010 

4 

RH000019 
~~~ Dangerous Goods Shipper Seminar 

~~ 

Final Test 

9. Which one of the following UN specification packages is acceptable to ship 18 L of UN 2749? 

' . A. UN 1B 1/X 1_.811~0/1 Q 

~ UN 4G/X22/S/09 

C. UN 4G/X12/S/08 

D. UN lAl!Y 1.41150/07 

10. What is the most important safety requirement in preparing a package containing dry ice? 

A. 

B. 

C. 

To put hazard labels on all sides of the package 

To make sure the dry ice is at the proper temperature 

To use a sturdy package and plenty of heavy dnty tape 

@ To ensure the dry ice is in packaging designed and constmcted to permit the release of carbon dioxide gas 

and prevent a build up of-pressure, 

11. How many kilograms of UN 3090 Primary Lithium batteries are allowed to be shipped on a passenger 

aircraft going from Atlanta to Los Angeles? 

A. 2.5kgG 

B. 35 kgG 

C. No maximum limit 

® Forbidden based upon USG-02 

12. Which of the follo"ing inner packaging (IP) is allowed for UN 2031 Packing Group I? 

@ GlassiPl 

B. Plastic IP2 

C. Metal IP3 

D. Aluminium IP3A 

January 2010 

5 

RH000020 
Final Test Dangerous Goods Shipper Seminar ~~ 

~4 

13. What packing group would you use to ship UN 1599 if the MSDS shows an Oral LD50 of 45 mgfkg, 

a Dermal LD50 of300 mglkg and no Inhalation tpxicity? 

· A. Packing Group I .. 

@ Packing Group ll 

C. Packing Group lli 

D. Not regulated as a toxic hazard 

14. What two test must the shipper conduct prior to shipping a Limited Quantity package? 

A. Cmsh and Puncture Test 

([) Drop and Stack Test 

C. Pressure Test 

D. Bursting Test 

15. What hazard label is required on the outer package for UN 1230? 

A. Conosive and Flammable Liquid 

B. Flammable Liquid and Toxic 

@ Flammable Liquid 

D. Miscellaneous 

January 2010 

6 

RH000021 
~~~ Dangerous Goods Shipper Seminar 

~~ 

Quantity: 1 US gallon 

Final Test 

TEST CASE 

Packaging available: 2 UN specification outer packages 

(Inner packaging allowed by the packing instruction is 

Consignee: 

Airwaybill #: 

Emergency Telephone #: 

Airport of Destination: 

assumed to be correct) 

Patrick Alexander 

Exfoilants, Inc. 

15080 San Pedro Avenue 

San Antonio, TX 78232 

258652436996 

(210) 222-3458 

San Antonio 

Performance Steps 

0 Identify the Proper Shipping Name. T "::> D 'o l> \-'1. r~ \ e_h \ tN" ,· cl.-t0 Identify UN/ID number, class/division, packing group, hazard labels .. 

\)t\)'2.:::,~ ~ 3 (_~)I :IT, ~\l)..~lV"'\0\.~\i. '--'W\~ ...\ (:()y'("O~\~ 

0 Select the most appropriate packing instmction based on the shipping 

scenario. -:)(.)~ 

0 Prepare your shipment in accordance with the packing instruction and 

packagingavailable.-:('P~ :Lr-l'\.-'( /40\~5/s [bq ou+bx 

0 Mark and label your package as appropriate. 

u~Z~<\S -r.~obu-l-~rl11 ~\ov~de. 'L\ Ll-k,v__s / L~bJ~ 'fL /t 1r:_oA 

0 . Compete the Shipper's Declaration. / l 

7 

January 2010 

RH000022 
DOT HAZMAT SECURITY AWARENESS MODULE 

FINAL TEST 

NAME J'>o..:-n ~-lV\ ~ ~CX..Y>.L~-\ 

COMPANY 1\'\)...t\.~\) ~\0\.y;J_ O~'A 

DATE '1('2---dZ()l D 

Om SCORE: /V (CIRCLE YOUR ANSWER. EACH QUESTION IS 10 POINTS) 

1. Many materials that are classified as hazardous materials are essential products to industry, but 

potentG deaj) weapons in the hands of terrorist? 

• TRUE . FALSE 

2. Hazardous materials are least vulnerable when in transit? 

• TRUE~ 

3. Casual discussions with strangers along transpmtation routes about loads and destinations are 

encouraged by gener curity standards? 

• TRUE FALSE 

4. Some mixtures containing hazardous materials can cause a powerful explosion if detonated or 

ignited? • e FALSE 

5. One easy way to increase security of hazardous materials in transportation is to lock all doors of 

transp~les? 

·~FALSE 

6. The ~eats are internal? 

7. With 

·~ 

the use of commonplace equipment like scanners and color printers, a driver's license, 

certifications, passports, and other types of personal identification can be forged? 

·~FALSE 

8. All terrorists fit a ~ived picture of a criminal? 

• TRUE~ 

9. A careful employee background check and verification of information provided on an 

emplo~lication can be an effective deterrent to the insider threat? 

·~FALSE 

10. When you are questioned about hazardous materials transportation it is important that you know 

the pe~g and that he or she has a need to know? 

·~FALSE 

RH000023 
FedEx Express 

ICAO/IATA Dangerous Goods Seminar 

Final Test- Answer Sheet 

Name: \)~h \~J ~lf\t..-:-. t Date: -tlz<llZDI D 

Company name: -V-.o..~hD -\--\.()~~CAtaJ t·2Sl8 

Location of training: \Xx~1Po-.5 

Instructor: \J \\1\ 'A '1\ pa~Yb\b-Yj I { ' 

- __ / ··~ -.. , . .-~ ~---

~ §. £ Q 

1 • 0 0 0 

2 • 0 0 0 

3 0 0 • 0 

4 0 0 0 • 5 0 0 0 • 6 0 0 • 0 

q q 7 0 0 0 • 8 • 0 0 0 

9 0 • 0 0 

10 0 0 0 • 11 0 0 0 -~ 12 • 0 0 0 

13 0 • 0 0 

14 0 • 0 0 

15 0 0 • 0 

Test Case (continued) 

Fill in the blanks below: 

1. What "packing instruction" did you select for this shipment? 

2. What is the maximum quantity allowed "per package"? IDL 

3. What "inner container" did you select for this shipment"? 

4. What is the maximum quantity allowed in "each inner container"? 5L 

5. How many "inner containers" are needed to ship this commodity? 

RH000024 
;a 

::z: 

0 

0 

0 

0 

N 

Ul 

From the two packages shown below, select the appropriate package based on from 

previous page. Mark and label the outer packaging: 

r-:--;-F -:it "11 !j L 

ij---d 

Complete the Shipper's Declaration on the following page. 
~!~ Dangerous Goods Shipper Seminar Final Test 

SHIPPER'S DECLARATION FOR DANGEROUS GOODS (Provide at least three copies to the airline.} 

Shipper \--\ 

7\CA_cl_~ Air Waybill No. d, S ~ lo '5 A \..l ~ (!/11flp \) ~ \\A.Y'..J 1 \..) S'A 

~11L\.~ C::-u\t' ~""("-t...-t.W~ Page , of I Pages 

\\cus+~, 13 -noll Shipper's Reference Number 

. S\'-\ {oplional) 

Consignee • £ )(_ +c::\ \ Qy"\-\ s I T ,.._ c_ 

cA0 PQ.-\-v .. ,~.t .. f\\"-.tt\~ 

\IZ> D ~"~C\.v-- \'~v-o~~~n~ 1'\ SAl~.') A t"\I.D ;\x. '1 l~?. l }"JI 

Two completed and signed copies of this Declaration must WARNING 

be handed to the operator 

TRANSPORT DETAILS Failure to comply with all respects with the applicable 

This shipment is within the Airport of Departure Dangerous Goods Regulations may be in breach of 

llml!allcns prescribed lor: the applicable law, subject to legal penalties. (delete non applicable) l CARGO \~~u":J\DY\ ~~ ~ 

AIRCRAFT 

ONLY 

Airport of Destination: 5 P. ~ ~f\\-nn ~l'l Shipment type: (delete non-applicable) 

NON-RADIOACTIVE "Ro!<S!e!>'<61'1 ... E 

NATURE AND QUANTITY OF DANGEROUS GOODS 

Dangerous Goods Identification 

UN C!.us Quantity and Packing Pack· Authorization or type of packaging Ins!. Proper Shipping Name orDio'ision jng ID (Stbs.idiary 

No. Risk) Oroup 

UtJ J:scb .. d·'j.,.q I Chton~t. 3(<a) --rr \ ~~f'~r~~ 30'7 23~'5 \3D.*X 4 t:dvts 

/1 ,.'/ 

-:-- ------------'----'---------------------

Additional Handling Information dol.\ \\ ( · C...C --\; -j- O\JY" 'N"\'t.,v-~"-''"'e ~ n i:I..C 

~~• v-o..tcct.\ "1-t.\-o n'.-11'1'1'\t \1\VM'ru..'r ~tlxvJ.-rM.. \- &()1)- 5S~- 12-1'2 

I hereby dec";;re that the contents of this consignment are fully and Name!Ji!le of Signal~ 

accurately described above by the proper shipping name, and are DA\'\11\..l th?..~ ~'E"'\\o\"'l~t.\ Di~bJ~~ classified, packaged, marked and labelled/placarded, and are in all Place and Date (Y\~Vrespects In proper condition for transport according to applicable Wbt>*bl'"'\ 1\£..~ llo International and National Governmental Regulations. I declare thai 

all of the applicable air transport requirements have been mel. ( Signature 

CJ,., l'iUY'\ :\ 

nt.... 1-~0D 

Em~~ncy 

- 55 

Te:ephone 

-f ZJ"l. Number ~·m~D~~ 

FOR RAOIOACTIV~ MAT~RIAL SHIPM~NT ACCEPTABLE FOR PASSENGER AIRCRAFT. THE SHIPMENT CONTAINS RADIOACTIVE MAT~RIAL INTEND~D FOR USE IN OR 

INCIDENT TO RESEARCH. MEDICAL DIAGNOSIS. OR TREATM~t>IT. AOR EUROPEAN TRANSPORT STATEMENT: CARRIAGE IN ACCORDANCE WITH l. t4.2.1 

January 2010 5 

RH000026 
REDACTED 

REDACTED 

- • 

-

REDACTED 

l REDACTED 

From: cart Luning 

Sent: Thursday, April 07, 2011 5:00PM 

To: Darren Hamaoki; RHUSA Service Engineers; RHUSA Service Coordinators; RHUSA Warehouse Coordinators; RHUSA 

IntiService 

Cc: RHUSA Branch Managers; RHUSA Branch Administrators; RHUSA PMD; Anna Lane; Arlene Follett; RHUSA 

Management Team 

Subject: RE: Butane Soldering Irons (Butane) 

Importance: High 

Good Day Everyone, 

I have completed my discussions with the FAA representatives regarding the Butane Irons. There is a large disconnect 

between the FAA and TSA. Since the TSA sets their own policies and procedures, the FAA has little control over the 

TSA. Although both entities follow the air commerce regulations set forth (CR 49), the TSA will have random selection 

that will inevitably become an issue again. Because they could engage with a random selection with the irons or inspect 

the vale, smelling any amount or seeing residue, it is at their discretion to have another investigation set forth. With this 

said, Radio Holland USA cannot allow these tools to be carried in checked baggage or in carryon baggage for any air 

craft. 

My original statement stands, we are not allowed to have Butane Irons on any aircraft due to the air commerce 

regulations. 

RH000027 
In the meantime, work with your RM's to find a secondary solution with wireless irons on the small projects and corded 

irons when convenient. 

I will continue to review the needs with the RM's and see if we can make this a painless as possible for you. 

RM's ..... please ensure you have an extra Butane Iron in your depots in case we have folks traveling for assistance. 

Kind Regards, 

tariLi:ining 

National Service Manager 

Radio Holland USA, Inc. 

8943 Gulf Freeway 

Houston, TX 77017 

T: +1-713-378-2166 

F: +1-713-943-2183 

E: carlluning@radiohollandusa.com 

1: www.radiohollandusa.com 

Radio Holland is a member of lmtech Marine Group 

From: Carl Luning 

Sent: Monday, April 04, 2011 10:16 AM 

To: Darren Hamaoki; RHUSA Service Engineers; RHUSA Service Coordinators; RHUSA Warehouse Coordinators; RHUSA 

Inti Service 

Cc: RHUSA Branch Managers; RHUSA Branch Administrators; Rich Beattie; RHUSA PMD; Anna Lane; Arlene Follett 

Subject: RE: Butane Soldering Irons (Butane) 

Darren, 

Thanks for the feedback. I will see how the investigation goes and will decide if this is an alternative we can proceed 

with. 

Thanks, 

Carl 

From: Darren Hamaoki 

Sent: Monday, April 04, 2011 10:00 AM 

To: carl Luning; RHUSA Service Engineers; RHUSA Service Coordinators; RHUSA Warehouse Coordinators; RHUSA 

IntiService 

Cc: RHUSA Branch Managers; RHUSA Branch Administrators; Rich Beattie; RHUSA PMD; Anna Lane; Arlene Follett 

Subject: RE: Butane Soldering Irons (Butane) 

Carl, 

I understand the FAA has their own set of rules to go by and can make their own decisions because practically every 

smoker carries a butane lighter and has an ignition device built into it and im sure they do not catch thousands of those in 

security checks. However, no sence poking the sleeping bear. In this case would they be convinced if we removed the 

valve completely from the iron and taped the vale in a baggy to the iron, that way there would be no doubt that only air is 

inside. The valve just on screws with a common screwdriver. 

2 

RH000028 
Best Regards, 

Radio Holland (CANADA) Ltd. 

Darren Hamaoki 

Service Manager 

T +1 604 293 29 00 

F- +~604 293 29 30 

E darrenhamaoki@radioholland.ca 

I www.radiohollandgroup.ca 

Radio Holland is a member of Imtech Marine B.V. 

From: Carl Luning 

Sent: Mon 4/4/2011 8:28 AM 

To: RHUSA Service Engineers; RHUSA Service Coordinators; RHUSA Warehouse Coordinators; RHUSA IntfService 

Cc: RHUSA Branch Managers; RHUSA Branch Administrators; Rich Beattie; RHUSA PMD; Anna Lane; Arlene Follett 

Subject: Butane Soldering Irons (Butane) 

Good Day Everyone, 

RHUSA recently received notification of an alleged violation of Title 49 Code of Federal regulations (49 CFR), pertaining 

to the transportation of hazardous materials in air commerce. The FAA is investigating an incident where a Butane 

Soldering iron was in checked baggage on an airplane. Even thought the soldering iron had been empted of the Butane, 

there are still minimal amounts in the solder iron, and in this instant, was deemed a potential violation (still under 

investigation). 

At this moment in time, I am banning all Butane Soldering Irons from being taking onto any aircraft, in checked baggage 

or otherwise. Simply, this means no Butane Soldering Irons permitted by air travel for RHUSA personnel. We will need 

to carry electric soldering irons if needed or borrow from the local office within the Branch/Region as necessary. 

I expect you will adhere to this note immediately. Please let me know if there are any questions. 

I will follow up with everyone once the FAA investigation is complete. 

Kind Regards, 

Carl Luning 

National Service Manager 

Radio Holland USA, Inc. 

8943 Gulf Freeway 

Houston, TX 77017 

T: +1-713-378-2166 

F: +1-713-943-2183 

E: carlluning@radiohollandusa.com 

1: www.radiohollandusa.com 

Radio Holland is a member of lmtech Marine Group 

3 

Rwnnnn,Q 
-~-- ..... ·-·REDACTED -· 

From: 

Sent: 

To: 

Subject: 

From: 

Sent: 

Rich Beattie <Rich.Beattie@imtechmarine.com> 

Wednesday, July 17, 2013 1:54PM 

Urs Rathgeb 

Emailing: Butane%20Soldering%20Irons%20(Butane).htm 

- -~ ~ .. 

Carl luning 

Monday, April 04, 2011 8:29AM 

To: 

RHUSA Service Engineers; RHUSA Service Coordinators; RHUSA Warehouse Coordinators; 

RHUSA lntiService 

Cc: 

RHUSA Branch Managers; RHUSA Branch Administrators; Rich Beattie; RHUSA PMD; Anna 

lane; Arlene Follett 

Subject: Butane Soldering Irons (Butane) 

Importance: High 

Good Day Everyone, 

RHUSA recently received notification of an alleged violation of Title 49 Code of Federal regulations (49 CFR), pertaining 

to the transportation of hazardous materials in air commerce. The FAA is investigating an incident where a Butane 

Soldering iron was in checked baggage on an airplane. Even thought the soldering iron had been empted of the Butane, 

there are still minimal amounts in the solder iron, and in this instant, was deemed a potential violation (still under 

investigation). 

At this moment in time, I am banning all Butane Soldering Irons from being taking onto any aircraft, in checked baggage 

or otherwise. Simply, this means no Butane Soldering Irons permitted by air travel for RHUSA personnel. We will need 

to carry electric soldering irons if needed or borrow from the local office within the Branch/Region as necessary. 

I expect you will adhere to this note immediately. Please let me know if there are any questions. 

I will follow up with everyone once the FAA investigation is complete. 

Kind Regards, 

Carl Luning 

National Service Manager 

Radio Holland USA, Inc. 

8943 Gulf Freeway 

Houston, TX 77017 

T: +1-713-378-2166 

F: +1-713-943-2183 

E: carlluning@radiohollandusa.com 

1: www.radiohollandusa.com 

Radio Holland is a member of lmtech Marine Group 

Dl.lnnnn-»n