W. R. Grace Co.-Conn — Hazardous Materials Safety Interpretation

Page 1• i U.S. Department of Transportation Washington, D.C. 20590 400 Seventh Street, S.W. Research and dministratior pecial Program AUG 27 2001 Capt. Sam Rogers National Cargo Bureau Inc. Ref. No. 01-0179 90 West Street, Suite 2000 New York, NY 10006-1039 Dear Capt. Rogers: This is in response to your letter dated July 11, 2001, requesting clarification of marking reguirements Ior bul! ackages in the Hazardous Materials Regulations (HMR; 49 CEI tarts 111-180)• Specifically, you ask if a bulk package containing a hazardous material subject to § 172.203(k) must be marked with the technical name as specified in § 172.301 (b) for a non-bulk package. The answer is no. Ihere is no requirement in the HMR to mark a subject to § 172.203 (k). technical name on a bulk package containing a hazardous material I hope this satisfies your request Sincerely, JohnA! Gale™ Ixansportation Regulation Specialist Office of Hazardous Material Standards#

Page 2i, 07/11/2001 02:29 FAX 401 NATIONAL BAH "GARGO BUREAU $172.302 (d) •ING. c-mail: ncbnyce@natcargo.org Facsimile Letter Requesting Interpretation Marking Bulk Mr. Edward Mazzullo Department of Transportation, RSPA tackaginas Office of Hazardous Materials Standards (DHM-10) Washington, DC 20590-0001 01- 0179 Subject: Package Markings for other than Non-Bulk Packaging when declared under Generic or NOS Proper Shipping Names References: 49CFR, 172.302(d), 172.326(a) Dear Mr. Mazzullo, A iccurring situation exists pertaining to the marking requirements for large and bulk package, which warrants clarification. Within section 172.301 there is the expressed general marking requirements for non-bulk packagings. Paragraph (b) of this section ddresses technical name requirements in association with the proper shipping name As such, technical names where indicated by the symbol "G" in column i of the Hazmal Table, will require be a required marking on non-bulk packagings. In review of the bulk package marking requirements relating to this same issue, are non intermediate, large and bulk packagings pose greater risk than those in non-bulk existent. We feel that this may have been an oversight, in that materials loaded in packagings; and would also require the same package markings. Do the packages other than non-bulk, require the technical name(s) on the exterior of thesc, as part of the proper shipping name? Please provide us with your interpretation in order to avoid any confusion with the Internationally accepred methods/recommendations. •Best regards, Sam Rosm Capt. Sam Rogers Master Marnier Senior Hazmat Coordinator 90 WEST STREET • SUITE 2000 - NEW YORK, NEW YORK 10006-1039#