McClain E-Z Pack, Inc — Hazardous Materials Safety Interpretation

Page 1400 Seventh St., S.W. MAR 2 2 2002 Washington, D.C. 20590 Ref. No. 02-0068 McClain E-Z Ms. Jamie S. Morton-Richardson Pack, Inc. Oklahoma City, OK 73173 4000 S.W. 113th Dear Ms. Morton-Richardson: authorized packagings for "Solids containing flammable liquid, This is in response to your request for clarification of n.o.s.," UN3175 under the Hazardous Materials Regulations (HMR; container is authorized for this entry. You also ask whether You ask whether a roll-on/roll-off bulk Special Provision 47 means that a leakproofness test at the bulk container. Packing Group II level must be performed on a roll-on/roll-off Section 173.240 authorizes sift-proof non-DOT specification n.o.s.," UN3175. Roll-on/roll-off bulk containers that are closed bulk bins for "Solids containing flammable liquid, closed whereby contents cannot pass through, and meet the strong, firm, durable, constructed so that they are securely applicable requirements in SS 173.24 and 173.24b are authorized non-DOT specification closed bulk bins and do not require a containing flammable liquid, n.o.s." meeting Special Provision 47 leakproofness test. Provided these requirements are met, may be transported in the roll-on/roll-off bulk containers. have additional questions. I hope this information is helpful. Please contact us if you Sincerely, Hatte z mittle Regulatory Review and Reinvention Hattie I. Mitchell, Chief Office of Hazardous Materials Standards 020068 173.240#

Page 2MIn.ture §173.240, MCClain E-Z Pack, Inc. 3178.004 lestina 1000 $7 Packagings Tuesday, November 13, 2001 (405) 691-6311 • Fax (405) 691-4441 Oklahoma City, OK 73173 Mr. Edward Mazzullo 02 - 0068 RESPA Office of Hazardous Materials Standards - DHM-10 U.S. Department of Transportation 400 Seventh Street, Southwest Washington, DC. 20590-0001 Dear Mr. Mazzullo: I spoke with Mr. John Ramsey with the Hazardous Material Division in Oklahoma City, Oklahoma earlier today regarding the shipment of Solids, n.o.s. 3175 in bulk packages. He suggested we write to the Office of Hazardous Materials in Washington for clarification. Our customer is shipping Solids, n.o.s. 3175 in bulk packages. CFR 173.240 and 173.240(b) state the bulk container must be sift proof. However, special provision "47", states that the packaging has to have a leak proof test at packing group II level. Our sift proof package cannot be leak proof tested. What do we do ? Please accept our thanks for your assistance in advance. Ms. MR REQUESTS Respectfully, McClain E-Z Pack, LTR. TO AODRESS ROLL-ON /ROLL-OFF AS AUTHORIZED PRG. $ Jamie S. Morton-Richardson Geheral Manager whether it Recuires. McClain of Oklahoma A LEARPROOFNESS TEST AT THE PG.IT LEVEL. Cc: Mark Hess (Vopak) File a MCClain Group Company#