ADD South — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Washington, D.C. 20590 400 Seventh St., S.W. APR 1 - 2002 Ms. Becky Webber ADD South Ref. No. 02-0059 5790 S Semoran Blvd Orlando, FL 32822 Dear Ms. Webber: This is in response to your October 22, 2001 letter concerning shipping paper requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). We apologize for the delay in responding to your letter due to mail delivery problems many Federal agencies have been experiencing due to screening and decontamination precautions. Specifically, you ask if using bold print on the shipping paper meets the requirements of using a contrasting color when entering hazardous material descriptions on a shipping paper along with a material not subject to the HMR. Bold print is not considered a contrasting color. If a facility does not have access to color printing spit paper. 20 pi is ides ore opine to died is in te lazed us matin taper re including a column captioned "HM" (for Hazardous Material) and placing an "X" in the column for the hazardous material entries. I hope this satisfies your request. Sincerely, Ahma 765 els Delmer F. Billings Chief, Standards Development Office of Hazardous Materials Standards 172.201 020059#

Page 2donnsen 8172.201 60i Shipping Papers 02-0059 A Division of ADD Systems October 22, 2001 Ms. Hattie L Mitchell 400 7th St. SW Chief of Regulatory Review and Reinvention Room 8422 Washington, DC 20590 Dear Ms. Mitchell, We are a software provider to the petroleum industry. About ten years ago when our implemented the printing of these messages using bold print as the "contrasting color" company first began printing Hazardous Materials Messages on shipping documents, we because none of our customers had color printers. Printing in a contrasting color was really not an option in their environment. One of our customers recently told us that according to the DOT Regional Office in official ruling on this, as I'm told you are the one who makes the rules and the DOT just Baltimore, bold print was not an accepted "contrasting color". I am writing to you for an enforces them. Years ago, the ruling was that bold print was an acceptable contrasting color. Sincerely, Becky weaker Becky Webber ADD South 5790 S Semoran Blyd A Division of ADD Systems, Inc. Orlando, FL 32822#