North American Group — Hazardous Materials Safety Interpretation

Page 1Washington, D.C. 400 Seventh Street, S.W. 20590 Research and Administratior pecial Program: MAR 1 0 2000 Ms. Cassie Mayrand-Burney Ford Motor Company Ref. No. 00-0037 Safety Office QMP Building - Room 351-2 North American Group Dearborn, MI 48121 Dear Ms. Mayrand-Burney: This is in response to your letter dated January 31, 2000, regarding the transportation of aerosols under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically you ask if aerosols may be offered for transportation in packages that exceed 30 kg (66 pounds). Materials transported under the proper shipping name "Aerosols" must be packaged in accordance with $ 173.306. pounds) gross weight. Under § 173.306 each outside package may not exceed 30 kg (66 that meets the definition of consumer commodity may be renamed However, a limited quantity of aerosols consumer commodity and reclassed ORM-D (see $ 173.306 (h)). The 30 kg (66 pound) gross weight limitation does not apply to materials classed as ORM-D when shipped under the provisions of S 173.156 (b) (1) or (2). I hope this satisfies your request. Sincerely, Transportation Regulations Specialist Office of Hazardous Materials Standards 000037 173,306#

Page 2JAN 31 2000 14:34 FR TPC/O WEST PARK CTR 313 337 1949 TO 912023663012 P.02/02 BAL Fond Motor Company, $173.306 00-0037 Global Hazardous Materials North American Group Compliance Office Jamuary 31, 2000. To: Mr. Edward T. Mazzullo Director, Office of Hazardous Materials Standards U.S. DOT/RSPA (DHM-10) 400 7th Street S.W. Washington, D.C. 20590-0001 Subject: Request for Interpretation Regarding the Shipment of Acrosol Cans I am writing to request a written interpretation from the Office of Hazardous Materials Standards for hazardous material table (172.101), from the manner it is presented on the table, it implies Aerosol cans clarification in regards to the shipment of aerosol cans above the 66 pound limit. Referencing the 49 CFR, (each not excooding 1 liter capacity) can be shipped fully regulated as 'Acrosol Cans, flammable (or non- flammable), 2.1, UN1950' at any quantity. Upon inquiry to the Department of Transportation, they had confusion is that there is no prohibited limit indicated as to how much you can ship other than under the stated that aerosol cans, if above the 66 pound limit are prohibited to be shipped as previously stated. The 'Exceptions' column, where it references 173.306. Here the regulation states that compressed gases cannot be shipped in 'limited quantities' if the package exceeds 66 pounds. Doesn't this mean acrosols can be QTY)? If this is not the case, could you please provide this office a written interpretation of this part of the shipped fully regulated and can exceed the 66 pound limit if shipped fully regulated and not as an LTD regulation for clarification and for our records. Thanks in advance for your assistance with this matter. Sincerely, 'assie Mayrand-Burne: needs lette stating "Aeross" is a etd gty ajit i restricied to 661b S4sS ** TOTAL PAGE.Ø2.**_ -#