Logistics Services Two Limited — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department Washington, D.C. 20590 400 Seventh St., S.W. Special Programs Research and Administration APR - 6 2001 Mr. Michael F. Ryan Regulatory Specialist Ref. No. 01-0013 Limited Logistics Services Iwo Limited Parkway Columbus, Ohio 43230 Dear Mr. Ryan: responds to your letter requesting clarification of the mixed contents packaging requirements for safety matches under § 113.186 (C) of the Hazardous Materials Regulations (HMR; 49 CFR follows: 171-180). Your questions are paraphrased and answered as Q1. The exception in § 173.186 (c) specifies that safety matches may only be packed in the same outer packaging with materials not subject to the HMR. May safety matches be packaged in the same outer packaging with a Consumer commodity, ORM-D, if the outer package is marked for both hazards? Al. The answer is no. A Consumer commodity, ORM-D, is subject to the HMR and, therefore, may not be packaged in the same outer packaging under the exceptions for safety matches in s 113.186(C). You may, however, overpack fully regulated hazardous materials with excepted packages of safety matches provided the overpack conforms to all applicable requirements of the HMR. See § 173.25. 22. May safety matches be packaged in the same outer packaging with a Class 3 or Division 2.1 material provided the package is marked and labeled for all hazards? A2. No. See answer Al above. In addition, depending on the node oi transportation used, overpacked packages of lazardous materials are subject to the searegation and quantity, limitation requirements under Parts 174-177 of the 03. Are safety matches permitted to be overpacked (shrink- wrapped onto a pallet) with a Consumer commodity, ORM-D?#

Page 2Yes, under certain conditions. are independently packaged as specified in $ 173.186, they Provided the safety matches may be overpacked (shrink-wrapped) onto a pallet with any compatible material, hazardous or otherwise. See S$ 173.25 and 173.156. be of further assistance. I trust this satisfies your request. Please contact us if we can Sincerely, Hotte 2. mitchell Hattie I. Mitchell Chief, Regulatory Review Office and Reinvention of Hazardous Materials Standards#

Page 3Stevens Q173.186 (° January 8, 2001 - Ms. Hattie L. Mitcheli Packaging Chief, Regulatory Review and Reinvention United States Department of Transportation Office of Hazardous Materials Standards 01-0013 DHM-12 400 7 Street, S.W. Washington, DC 20590-0001 RE: Clarification of 49 CFR 173.186(c) - Dear Ms. Mitchell: We would like to request a clarification to 49 CFR 173.186(c) regarding the shipment of satety matches. Specifically: 1. Can safety matches be packed into the same outer package with consumer commodities (ORM-D) provided that the outer package contains the appropriate • markings for both hazards? 2. Can safety matches be packed into the same outer package with flammable liquids (Class 3) or aerosols (Division 2.1) provided that the outer package contains the appropriate markings and labels for all hazards? 3. Can safety matches be overpacked (shrink-wrapped onto a pallet) with consumer commodities? We are looking forward to your response. sincerely ..- Michael F. Ryan Regulatory Specialist Limited Logistics Services Two Limited Parkway Columbus, OH 43230#

Page 4- - THELIMITED, INC. LUMBER F TWO LIMITED PARKWAY JAN -B'01 COLuMBuS, OHIO 43230 • 3 ! OHIO 3hr- ..:'e -060924 Ms. Hattie L. Mitchell United States Department of Transportation Chief, Regulatory Review and Reinvention Office of Hazardous Materials Standards 400 7" Street, S.W. DHM-12 Washington, DC 20590-0001 2059010001 - ...-#