Midwest Rubber Mfg., Inc. — Hazardous Materials Safety Interpretation

Page 1J.S. Department f Transportatior 40D Seventh Street, S.W Nashington, D.C. 20590 Special Programs Research and Administration JUN 5 2000 Ms. Darlene Rauk Midwest Rubber Mfg., Inc. P. O. Box 207 Ref. No. 00-0144 250 Industrial Circle Stoughton, WI 53589 Dear Ms. Rauk: This is in response to your letter dated May 5, 2000 requesting verification on the proper shipping of Adhesives, 3, UN 1133, PG II. You ask if it is possible to ship 8 oz. cans in a case of 24, weighing 13 Ibs. per case, without labeling the cans. You further state that the case would be palletized and shrink-wrapped. The labeling requirements found in 49 CFR 172.400 require each non-bulk package (i.e., case) to be labeled with the label specified in the § 172.101 Table for the material. In your situation, the hazard warning labels are only required on the outside package and are not required to be placed packages are not visible, the label and other markings must be placed on the shrink-wrapped film- on inner packages (i.e., cans). If several cases are shrink-wrapped, and the labels on the overpack. See § 173.25. I hope his information is helpful. Sincerely, Hotte z, Mitchell Hattie L. Mitchell Chief, Regulatory Review and Reinvention Office of Hazardous Materials Standards 172.400 000144#

Page 2corbin $ 172.400 P.O. BOX 207, STOUGHTON, WISCONSIN 535BS MIDWEST RUBBER MFG., INC. 00 - 0144 PHONE 608/873-7788 FAX 60B/B73-5880 May 5, 2000 Attn: Edward Mazzullo (fax - 202-366-3012) Department of Transportation Hazardous Material Dept From: Midwest Rubber Mfg., Inc Darlene Rauk (fax - 608-873-5880) PO BOX 207 - 250 stoughton, WI 53589 Industrial Circle Pages: 1 Regarding: Labeling of shipping hazardous materials Dear Mr. Mazzullo: shipping of the following. ADHESIVES, 3, UN 1133, PG II. I was informed to contact you for verification on the proper We have a customer who has requested if it is possible to labeling the cans. ship, 8 oz cans in a case of 24, 13 pounds per case, without them. We would label the outside of the case with all the They would like to label them when they come to possibility of non-hazardous products. specified labels, the case would be put on a pallet with a with extra cardboard and more stretch wrap and labels will also be We stretch wrap the pallet put on the outside of this. verification of this as soon as possible. Thank you. I would like a written sincerely, Dartene Rank Darlene Rauk OHIO OFFICE: P.O. Box 5393 Fairlawn, OH 44334 Phone: (330) 867-6262#