UPS Corporate Hazardous — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department Washington, D.C. 20590 400 Seventh St., S.W. DEC 27 2001 Ms. Mary Beth Schommer UPS Corporate Hazardous Ref. No. 01-0316 Materials Manager 55 Glenlake Parkway NE Atlanta, GA 30328 Dear Ms. Schommer: This is in response to your letter dated December 18, 2001 requesting a review of your proposed shipping labels for compliance with the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if the incorporation of the ORM-D markings into the UPS bar coded address label will meet the marking requirements under the HMR. You provided three examples of UPS bar coded address labels containing the ORM-D markings. The answer is yes. Section 172.304(a)(4) states that the required marking (proper shipping name and identification number) must be located away from any other marking (such as advertising) that could substantially reduce its effectiveness. The required markings appearing on your enclosed labels are readily distinguishable and satisfy this requirement. I hope this satisfies your request. Sincerely, Delmer F. Billings Chief, Standards Development Office of Hazardous Materials Standards 172.304 010316#

Page 2MAR 10 '00 07:37 FR • TO 912023653012 P.02/05 Ups United Parcel Service 55 Glenlake Parkway, NE Atlanta, GA 30328 (104) 828-6000 To: Date: December 17, 2001 From: Mary Beth Schommer - UPS Hazardous Materials Manager Arthur Pollak - Office of Hazardous Materials Standards Subj: UPS Label Mock-up Containing ORM-D Ground Markings UPS has been asked about the possibility of incorporating the ORM-D marking for Ground minking in he the to put separate markings on the package. Folowing are three mock up examples containing the consumer commodity markings on a UPS address and tracking label meeting our internal specifications. our system, there are a couple of versions containing the ORM-D marking. The two As there are two different sizes of address and tracking labels that are acceptable in were given verbal approval by Del Billings as being an acceptable option for a 4" X 8" samples (#1 and #2) were submitted for approval in the past month, and shipper to mark the consumer commodity regulatory information on a package. submitted for approval were not acceptable due to the close proximity of non- Sample #3 is a new example of the 4" X 6" label, whereas the previous two versions regulatory information, thus reducing the effectiveness of the markings. Based on the three current samples submitted, does D.O.T. feel the ORM-D marking been reduced? Your thoughts and comments are much appreciated. Contact me requirement in 172.304 is being met, and the effectiveness of the markings haven't requested in order for us to incorporate approved specifications into our internal with any questions, concerns or input you may have on this matter. A written reply is label requirements. Regards, Mary Beth Schommer Mary Beth Schommer 55 Glenlake Parkway N. E. UPS Corporate Hazardous Materials Manager Atlanta, GA 30328 Fax: Phone: 404-828-7425 404-828-4108 Email: mbschommer@ups.com 38 USE: 201 .. .....#