HB Fuller Company — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation 400 Seventh St., S.W. Washington, D.C. 20590 Research and Special Programs Idministration APR 2 6 2002 Mr. Gene Secor Reference No.: 02-0045 HB Fuller Company 25200 Malvina Avenue Warren, MI 48089 Dear Mr. Secor: This is in response to your letter concerning requirements for shipping consumer commodities under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask about the exceptions for ORM-D materials in § 173.156(b)(1). Your questions are paraphrased and answered as follows: Q1 Are outer packagings of combination packages the same as "boxes" as that term is used in § 173.156(b)(1)(i)? Yes. The outer packaging of a combination package meets the requirement for "boxes" for the purpose of unitizing under § 173.156(b)(1)(i). Q2. Are orientation markings required if the inner packagings contain liquid? A2. No. Packagings transported under § 173.156(b)(1) are excepted from the marking requirements in subpart D of part 172 of the HMR. Q3. May individual combination packagings containing liquids and marked "Consumer Commodity, ORM-D" be offered for transportation or must they be in another box or overpack? A3. Individual combination packages containing Class 8 (corrosive) materials, as described in 3 173.150 )ch and i, or hey may be ofted it cocoa me the the provin of § 173.154(c). I hope this satisfies your inquiry. If we can be of further assistance, please contact us. Sincerely, Transportation Regulations Specialist Office of Hazardous Materials Standards 173.156 020045#

Page 2FROM : FAX NO. : 8104471117 Feb. 11 2002 12:20PM_P2 Corbin 8173.156 February 11, 2002 US Department of Transportation ORM Exceptions DHM-12 Research and Spocial Projects Administration 400 Seventh St., S.W. 02-0045 Washington, D.C. 20590 Re: Orientation Arrows and ORM-D Gentlemen: for trcatment as limited quantities and, further, meet the definition of a Consumer Commodity allowing u We have several products that initially are classified as Class 8, Corrosives (PG II & III) that arc eligible o reclassify them to ORM-D. All of these are packaged in fiberboard cartons and marked on the carto: xterior Consumer Commodity, ORM-D. The inner reocptacles contain liquids. These ORM-D materia' Paragraph 173.156 Esceptions for ORM Materials at (b)(1) seems 10 indicate thaz ORM-D materials are excepted from the roquitements of Subpart D Marking Roquirements if/when certain sub requirements an completely clear: met. We comply with the sub requirements. This raises certain questions, the answers to which are nol 1. Is the outer of a combination package considered to be the "box or baxes" mentioned in 173.156 2. Is the requircment for use of Orientation Arrows on cartons with inners containing liquids excepted for (b)(I)I) since it is grouped with the words "similar overpacks?" 3. Can individual combination packages containing liquids, marked with Consumer Commodity, ORM- ORM-D materials? D, be shipped individually or do they have to be inserted into another box or overpack? Ansivers to these questions and interpretations would be appreciated. Sincerely, Here Decor Gene Secor HB Fuller Company : Warren, MI 48089 25200 Malvina Avenuc FAX: 586-447-1117 Phone: 248-526-4783 e-mail: gene.secor@hbfuller.com File: /DOT/Orientation Arrows and ORM-D#