DuPont Company — Hazardous Materials Safety Interpretation

Page 1U.S. Department Research and of Transportation 400 Seventh St., S.W. JUN 2 8 2002 Washington, D.C. 20590 Mr. Randolph Martin Ref No: 02-0147 Hazardous Materials Distribution Consultant DuPont Company 1007 Market Street, Room D-5100 Wilmington, DE 19898 Dear Mr. Martin: This is in response to your April 19, 2002 email requesting clarification of the shipping paper requirements in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you asked if you are required to use only UN specification packaging type names in meeting the requirements for identifying the type packages on shipping papers. The examples you referred to were pails, cans, cartons. In accordance with § 172.202 (5)(c), the total quantity of the material covered by one description must appear before or after, or both before and after, the description required and authorized by this subpart. The type of packaging and destination marks may be entered in any appropriate manner before or after the basic description. Abbreviations may be used to express units of measurement and types of packagings. In the International Maritime Dangerous Goods (IMDG) Code paragraph 5.4.1.1.1.5 requires the dangerous goods transport document contain information on the number and kind of packages and the total quantity of dangerous goods covered by the description (by volume or mass, and in the case of goods of class 1 by the net explosives mass of the contents). Although both the HMR and IMDG Code use the terms "type" and "kind" to describe packagings, no specific terminology or criteria is identified. Therefore, any appropriate terminology for packagings, such as pails, barrels, cans or cartons are acceptable. I hope this information is helpful. Please contact us if you require additional assistance Sincerely, Dilan 7 lo Delmer F. Billings Chief, Standards Development Office of Hazardous Materials Standards 172,202 020147#

Page 2Billings, Delmer rom: To: Sent: Subject: Package Descriptions Message Flag: Due By: Follow up Flag Status: Friday, April 19, 2002 5:00 PM Flagged Manny, appreciate ail your help in getting an interpretation letter from RSPA. Here is my complete name and address: Randolph Martin DuPont Company Hazardous Materials Distribution Consultant Wilmington, DE 19898 1007 Market Street, Room D-5100 04:04 PM Forwarded by Randolph Martin/AE/DuPont on 04/17/2002 Randolph Martin 01/24/2002 01:53 PM CC: To: epfersich@comdt.uscg.mil Subject: FW: Package Descriptions Manny, several months ago we got the attached e-mail from you indicating that package names are NOT limited to the use of UN packaging type names. We have passed this on to our carriers yet we continue to have several of interpretation letter on this subject that you can share with us, or absent them question our use of "pails, cans, boxes, etc". Do you have an are hesitant to accept your e-mail but have indicated that a letter on USCG that, could you prepare one that would address this subject? The carriers letterhead would have more weight. We would greatly appreciate any help you can provide. Please contact me on e-mail or call on 302-773-4248 if you have any questions. Thanks 01:44 PM - Forwarded by Randolph Martin/AE/DuPont on 01/24/2002 Randolph Martin 11/29/2001 02:55 PM To: Stephanie T Gaines/AE/DuPont@DuPont, Kimberly torgan/AE/DuPont@DuPont. Al Schvman/AE/DuPont@DuPont. Jo _averty/AE/DuPont@DuPont, mstevenson@bdpnet.com @ DuPont, A ipscomb/AE/DuPont@DuPont, Thomas C Reese/AE/DuPont@DuPont#

Page 3. cc: Mildred C Ruglass/AE/DuPont@DuPont, Kevin M Greene/HO/DuPont@DuPont Myoung@us.cattrans.com, William P Vanvliet/AE/DuPont@DuPont Subject: FW: Package Descriptions his clearly answers our question around use of various packaging name: are allowed. uch as pails, cans, cartons etc. The position of the USCG is that thei called the USCG on 11/27 and they mentioned just today that they got the exact same question from someone else (Dawn). 02:39 PM Forwarded by Randolph Martin/AE/DuPont on 11/29/2001 "Robinson, Brian" <BRobinson@comdt.uscg.mil> on 11/29/2001 02:24:37 PM To: Randolph Martin/AE/DuPont@DuPont Subject: CC: FW: Package Descriptions Here you go. From: Pfersich, Emmanuel —--Original Message--. Sent: Thursday, November 29, 2001 12:34 PM To: 'Abbaticchio, Dawn' Cc: Robinson, Brian Subject: RE: Package Descriptions Dawn, Manny From: Abbaticchio, Dawn [mailto: dabbatic@us.hsaclog.com] --Original Message-- To: Pfersich, Emmanuel Sent: Wednesday, November 28, 2001 9:00 AM Importance: High Subject: Package Descriptions Good Morning Mr. Pfersich, partner lines with regard to package descriptions. Some of the shipper have We have been in discussions with one of our big shippers as well as our (pails, cans, cartons, etc...) for years with no problem from carriers, been using descriptions that do not specifically appear inthe IMDG Code, inspectors or U.S Coast Guard. We now have a partner that will not accept 2#

Page 4• is: description not specifically spelled out in the IMDG - my question to you recommended in the IMDG Code be the description used? For example: metal Is it the interpretation of DOT that only the package descriptions receptacles instead of cans, boxes instead of cartons? Your guidance in this matter is appreciated. Hazardous Materials Specialist Dawn M. Abbaticchio email: dabbatic@us.hsaclog.com HSAC Logistics, Inc. (Columbus Line/Alianca/CAT} ph: 973-775-5300 pg: 973-606-0429 fx: 973-775-5318#