Aceto Corporation — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department 400 Seventh St., S.W. Research and Washington, D.C. 20590 Special Programs Administration AUG 16 2001 Mr. Simone A. Yearwood Aceto Corporation Ref. No. 01-0198 One Hollow Lane • Lake Success, NY 11042-1215 Dear Mr. Yearwood: This is in response to your July 23, 2001 letter concerning marking UN specification drums under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you wish to ship Pyridine in incorrectly marked UN specification drums. You may not transport Pyridine in incorrectly marked UN packagings. However, you may correct the UN specification marking (in this case, changing the "Z" marking to a "Y" marking) if you posses the valid test results that indicate the drum meets the "Y" specification criteria. Since your company is a different company than the company that originally marked the drums, you may not use the symbol representing the original company unless specific permission and arrangements, such as a written agreement, exist between your company and the original company. Enclosed is a previously issued letter from this Office that further clarifies the UN marking requirements. I hope this satisfies your request. Sincerely, fohn A. Gale Transportation Regulations Specialist Office of Hazardous Materials Standards Enclosure#

Page 2ACETO CORPORATION ONE HOLLOW LANE • LAKE SUCCESS • NEW YORK 11042-1215 PHONE: (516) 627-6000 • FAX: (516) 627-6093 E-mail: aceto@aceto.com • www.aceto.com Johnsen § 178.503 July 23, 2001 Packaging Markings Edward Mazzullo 01-0198 Director of OHMS US DOT/RSPA (DH-10) 100 7" Street, S.W Vashington, DC 2059 : Dear Mir. Mazzullo: Aceto Corporation requests that the OHMS confirm, in writing, that we are permitted to transport Pyridine received from India in incorrectly marked UN-Approved drums. The drum manufacturing company mistakenly marked the drums with "Z" instead of "Y". Aceto has documentation from our supplier, the drum manufacturer, and also the regulatory agency in India that approves UN-Approved packaging that these drums have met the criteria for shipment of Pyridine (pkg. I) and have incorrectly marked. Aceto Corporation will have copies of these documents accompany the shipments of these markings. drums. Aceto will also correctly label these drums with the appropriate UN-Approved DOT If you have any questions, please feel free to contact me at (516) 627-6000 ext.252 Best Regards, Sin a Yound Simone A. Yearwood Regulatory Affairs Specialist ACETO CORPORATION#