Maersk Sealand — Hazardous Materials Safety Interpretation

Page 1S. Departme 400 Seventh St., S.W. Transportatio Washington, D.C. 20590 Special Programs Research and NOV 2 6 2001 Administration Mr. Kevin J. O'Brien Ref. No: 01-0284 General Manager, Hazmat Policy & Compliance Maersk Sealand 5080 McLester Street Elizabeth, NJ 07207 Dear Mr. O'Brien: This is in response to your October 2; 2001 letter requesting clarification of requirements for completing a dangerous cargo manifest under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Your questions are paraphrased and answered as follows: Q. Is it necessary for the preparer to sign each page of a 50-page dangerous cargo manifest? A. No. Location of the signature anywhere on the same page as the certification statement constitutes signing the certification. Only one signed certification is required for a dangerous cargo manifest. Q. May the shipper use mechanical or electronic means to sign the certification? A. Yes. Consistent with shipping paper requirements a dangerous cargo manifest may be signed by typewriter or other mechanical means. Use of a typewriter, word processor or computer/printer to produce the signature satisfies this requirement provided the signature is made after the shipping information is entered on the dangerous cargo manifest. Q. Is one signed certification statement on the cover page of a multi page dangerous cargo manifest acceptable? A. Yes. I hope this information is helpful. Sincerely, Delmer F. Billings Chief, Standards Development Office of Hazardous Materials Standards 118730 010284#

Page 2A. R MOLLER IN G. MAERSK SEALAND lavalle October 2, 2001 onle.31 Mr. E. Pfersich Dangerous argoManifest United States Coast Guard Hazardous Materials Standards Branch G-MOS-3 2100 Second Street SW Signature Washington, DC 20593-0001 01-0284 Re: 49 CFR 176.30(b) - Vessel Dangerous Cargo Manifest Requirements Dear Manny: We would appreciate your assistance in clarifying certain CFR requirements on the references we are concerned about are 1) 176.30(b) signature of the person who prepared preparation of the vessel Dangerous Cargo Manifest (DCM). The two main CFR the manifest; and 2) 172.204(d)(2) allowing a shipper to use various means of signing the shipping papers. Our DCM is generated from a manifest system based on the booking information and a comparison of the shipper's hazardous papers against the booking before the manifest is including a line for the signature of the DCM preparer whose name is printed in capital printed. Our manifest page format pretty much follows the format suggested at IMO letters by the system. a) As some DCM's can be over 50 pages, is it necessary for the preparer to sign each Questions which have come up concerning this process are: b) As shipper's are allowed under 172.204(d)(2) to use mechanical or electronic means to sign the hazardous declaration, will the printing of the DCM preparer's name on Will just a signed certification statement on the cover page of the DCM satisfy the each manifest page by the system satisfy 176.30(b)? CFR requirement or must something also appear on each page? For operational reasons, your prompt response would be very much appreciated. 6-m50-3 2001-134 Sincerely: Force Oasi Kevin J. O'Brien General Manager, Hazmat Policy & Compliance MAERSK ING. email: 5080 Mclester Street, Elizabeth, N 07207 Prese Telephone: 908-558-6204: Fax: 908-558-6076. Internet: http://www.maersksealand.dk#