V.Ships Norway AS — Hazardous Materials Safety Interpretation

Page 1APR 29 2002 Washington, D.C. 20590 400 Seventh St., S.W. Mr. Sjur Gjerde Ref. No. 02-0063 SEQ Manager V.Ships Norway AS .O. Box 394, Skoyel rammensveien 145 l 0213 Oslo Dear Mr. Gjerde: This responds to your letter requesting clarification on the registration requirements regarding the shipment of equipment with residue of fuel in the tank as hazardous material under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180): Specifically, you ask if the equipment with a residue of fuel in the tank is subject to the HMR and registration requirements of Part 107, Subpart G of the HMR. According to your letter, you have techrical management on two reefer vessels which regularly trade between the United States and South America. These vessels occasionally carry various types of equipment such as generators with residue of fuel in the tank that are properly identified as a hazardous material. Each vessel operator, that is, each "person" as defined by the federal hazardous materials transportation law that has operational control of a vessel, that transports hazardous materials from United States ports to South America may be subject to the registration requirement if the materials being transported fall into the categories of materials that require registration. In addition, each person domiciled in the United States that performs a function pertaining to the offering for transportation or accepting for transportation, a hazardous material that is loaded on a vessel at a United States port may I hope this answers your inquiry. Sincerely, Shan IS o Delmer F. Billings Chief, Standards Development 173.220 Office of Hazardous Materials Standards 020063#

Page 2Drammensvaien 145 B 0213 Oslo P.O.Box 394, Skøyen Ph: +47 221 28 150 V.Ships Norway AS Fax: +47 225 61 089 Boothe www.vships.no § | 72 .22 HAZMAT Registration Manager 3107.601 DHM-60 Research and Special Programs Administration 400 Seventh Street, SW U.S Dep. Of Transportation kegistration Washington DC 02 -0063 Hazardous Materials, Certificate of Registration Reference is made to 49 CFR Part 107, Subpart G V.Ships Norway AS has technical management on two reefer vessels (Tundra Trader/ Tundra Consumer) regularly alling Us ports. They are trading between the US and South America, and they occasionally ship various equipmen hazardous material. Will such equipment, or in other words, such a small amount of a hazmat require this certificate? ack to SA. This may be generators etc, with residues of fuel in their tanks, and as such, may be classified as a We will appreciate if you could supply us with information regarding the said certificate, with respect to; -How do we proceed to obtain the certificate -Which vessels are required to have such a certificate onboard the Tundra Trader is issued to a time charterer (Lauritzen Reefers A/S). Will this certificate still be valid, -Is this certificate normally issued to the charter, operator or technical manager ? The present certificate provided the vessels are chartered by Lauritzen? We do appreciate your assistance in this matter for V.Ships Norway AS Best regards, jur Gente e-mail: sjur.gjerde@vships.no#