Thomas & Betts Corporation — Hazardous Materials Safety Interpretation

Page 1J.S. Department of Transportatior 400 Seventh St., S.W. Washington, D.C. 20590 Special Programs Research and Administration DEC 27 2001 Ms. Anna West Ref. No. 01-0265 Thomas & Betts Corporation 200 Challenger Drive Portland, TN 37148-1719 Dear Ms. West: This is in response to your October 2, 2001 letter and subsequent telephone conversation with a member of my staff requesting clarification of the provisions in § 173.153 of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to limited quantities. You state you are shipping packages of isophorone disocyanate under the description "Isophorone diisocyanate, 6.1, UN2290, PG III." Specifically, you request the proper labeling and marking requirements for 150 to 500 grams of isophorone diisocyanate (packaged as described in your letter) as a limited quantity under § 173.153. The packaging must be marked "Isophorone diisocyanate", and marked with the consignee's or consignor's name and address unless excepted by § 172.301(d). The packaging (unless the package is hermetically sealed) must be marked with orientation arrows as specified in § 172.312 and labeled with the POISON label in accordance with § 172.400. I hope this satisfies your request. Sincerely, Delmer F. Billings Chief, Standards Development Office of Hazardous Materials Standards 173.153 010265#

Page 2- BAH $173.22 Shipper's Responsibility 01-0265 October 2, 2001 Mr. Edward T. Madzullo Director of HM Standards USDOT/RSTA "DHM-10" 400 7" Street S.W. Washington, D.C. 20590-0001 Dear Mr. Madzullo: The Thomas & Betts plant at Portland, Tennessee is shipping ISOPHORONE DIISOCYANATE, 6.1,UN2290, PGIII. This is packaged in a foil packet, then sealed in a plastic bag. The quantity ranges from 150 grams to 500 grams per packet. Each part number is made up of several packets per carton (cardboard carton). We would like the proper shipping and labeling information in writing, please. We ship I have discussed this with HMDOT by phone, but would greatly appreciate your the cartons by Fed-x ground and Fed-x express (air), also by over the road carriers (LTL). information in writing for our files. Thank you for your response. Very truly yours, Anna Anna West Thomas & Betts Corporation aw Thomas&Betts -#