Williams Laboratory Services — Hazardous Materials Safety Interpretation

Page 1400 Seventh St., S.W. Washington, D.C. 20590 special rograms Administration SEP 17 2001 Ms. Jan Johnson Supervisor of Business Operations Reference No. 01-0220 Williams Laboratory Services 1090-A Sunshine Road Kansas City, Kansas 66115 Dear Ms. Johnson: "Materials of Trade" under the Hazardous Materials Regulations (HMR; 49 CFR parts 171-180). This is in response to your August 21, 2001 letter requesting clarification of the definition for Specifically you ask if hazardous materials transported between your company's facility and a laboratory for testing purposes, may be considered materials of trade. One criterion for a material of trade is that a hazardous material is transported by a private carrier in direct support of its principal business which may not be transportation by motor vehicle. Provided all conditions of § 173.6 are met, the materials of trade exception may be applied in your scenario. I hope this information is helpful. sincerely Shantatio Delmer F. Billings Chief, Standards Development Office of Hazardous Materials Standards 1134 010220 -..#

Page 2AUG-21-2001 15:52 WILLIAMS LAB 913 621 3603 P.02/03 Betts $171.8 Williams. Definition Laboratory Serviccs 1090-A Sunshine Roud 01-0220 913/621-3603 Kansas Ciry, Kansas 66115 August 21, 2001 US Dept of Transportation Office of Hazardous Materials Standards A Singo, Sc 2050 The purpose of this letter is to determine whether the hazardous materials carried on company trucks within the Williams Companies apply to Materials of Trade. Williams, through its subsidiaries, connects businesses to energy. We deliver innovative, reliable products through extensive networks of energy-distributing pipelines. Our primary businesses include: • Services from wellhead to burner tip • Nationwide system of interstate natural gas pipelines Several of our locations transport limited quantities of petroleum products (Class 3) and cylinders containing a gas (Class 2.1) not weighing more than 220 pounds, pressure per container 500-1000 psig. DOT Exemption 8757 and DOT Exemption 7657 apply to the cylinders used for these product samples. These samples are transported by company vehicles on public highways to a laboratory for testing purposes. Please advise whether the hazardous materials that are carried in our company trucks the driver of these trucks carrying non-bulk, combination packaging and less than 1000 apply to Materials of Trade. If not, please specify the proper paperwork to be carned by Ibs. gross aggregate weight Your prompt response these questions is appreciated. Sincerely, Jan Gahnsen Jan Johnsen Sup'y of Business Operations -#