Lilly Industries, Inc. — Hazardous Materials Safety Interpretation

Page 17. ' Engrum LILLY 8173. 173(4(2) Lilly Industries, Inc. • Packaging : August 21, 2000 00: 0236 Mr. Edward Mazzullo Director, Office of Hazardous Materials Standards USDOT/RSPA (DHM10) 400 7" Street Southwest washingion, D.C. 20590 - Dear Mr. Mazzullo, I am requesting written clarification and verification with regard to several questions related to UN-performance packaging for paint. The first questions relate to the exemption provided for paint. 49 CFR 173.173(b)(2) states that paint shipped in metal packaging of not over i gallon each, packed in a strong outer packaging are exempt it packages conforn to subpart B requirements. We are shipping paint in 1 gallon containers that meet subpart B requirements. The questions are: what constitutes a "strong outer. • packaging" and are we indeed exempt from having UN-performance packaging per 49 CFR 173.173(b)(=)? :. The next question is related to the UN-performance packaging specifications. Can UN- marked/tested weight uf the outer box? pertormance packaging be used even if the total weight of the container slightly exceed the • I have enclosed a telephone log from a conversation an individual at our corporate cffice had with Liz at the USDOT Hazardous Materials Information Line. At this time I am requesting written verification and clarification to these questions. If you have any questions or need further information, please do not hesitate to contact me at 309- 762-7546. Thank you. Sincerely, Shere Adams Sheri Adams Compliance Manager Lilly Industries, Inc. Moline Enclosure 5400 23rd. Avenue • Moline, IL 61265 • TEL (309) 762-7546 • FAX (309) 762-9604#