FedEx Ground Safety Department — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department 400 Seventh St., S.W. Special Programs Research and Washington, D.C. 20590 Administration JUN - 4 2001 Mr. Jerry w. Freeman Ref. No. 01-0105 ISM Manager Hazardous Materials Administration 1000 FedEx Drive FedEx Ground Safety Department Moon Township, PA 15108 Dear Mr. Freeman: This is in response to your letter dated April 23, 2001, concerning modification of the shipper's certification on shipping papers under the Hazardous Materials Regulations the words "and requirements of FedEx Ground" may be added to (HMR; 49 CFR Parts 171-180). Specifically, you asked whether the end of the certification statement specified in § 172.204 (a) (1). The answer is no. The certification statement specified in $ 172.204 (a) (1) :must be written as specified and may not be modified. Thus, it is unacceptable to include additional wording in association with the certification language stated in 172.204 (a) (1). The HMR, however, do not preclude an additional, separate statement on the shipping paper indicating that the lading is also shipped in accordance with FedEx Ground requirements. I hope this satisfies your request. Sincerely, Plund 3: Mazelle Edward 1. Director, Office of Hazardous Materials Standards 172.204 (a)(1) 010105#

Page 21000 FedEx Drive Moon Township, PA 15108 -Telephone 412.269.1000 Fax 412.262.6246 BAIt 8172. 204 )C) FedEx. Ground Shipper's Certification 01-0105 April 23, 2001 Information Center Office of Hazardous Material Standards Research & Special Programs Administration United States Department of Transportation 400 Seventh Street, S.W., Washington D.C. 20590-0001 I am writing to you on behalf of FedEx Ground Package System Inc., to get clarification on the Hazardous Material Regulations. My question pertains to the shipper's certification statement required by 49CFR Part §172.204: The FedEx Ground hazardous material certification forms and shipping papers, used by our customers, conform to all. . the requirements of 49CFR Part 172 Subpart C. Is it acceptable to add the words Hand. requirements of FedEx Ground" to the end of the certification statement specified in §172.204(a)(1)? 1 appreciate your time and consideration in this matter. Should you have any questions, please do not hesitate to contact me at 412-262-7351. Respectfully, my W. Creaman Jerry W. Freeman, TSM Manager Hazardous Materials Administration FedEx Ground Safety Department W'inner of American Tracking Associations' Prasident's Award for Safety.#