AAPER Alcohol — Hazardous Materials Safety Interpretation

Page 1• of Transportation U.S. Department 400 Seventh St., S.W. Research and Washington, D.C. 20590 Special Programs Administration AUG 27 2002 Ms. Linda Whitton Traffic Manager Ref. No. 02-0180 AAPER Alcohol P.O. Box 339 Shelbyville, KY 40066-0339 Dear Ms. Whitton: This is in response to your June 12, 2002 letter, requesting an opinion of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the requirements and standards for cartons. Specifically, you state your company ships Ethyl Alcohol, Class 3 (flammable liquid) in corrugated rectangular cartons and uses corrugated inserts to cover the open area of the inner flaps of your pint cartons. You question if corrugated inserts are a requirement of the HMR. You further indicate your intention to submit the cartons for re-certification without the corrugated inserts provided they are not required. Based on the information you provided, this Office can not determine if corrugated inserts are necessary to obtain re-certification of your cartons. Non-bulk Performance-Oriented Packaging Standards are found in Subpart L of Part 178. The testing requirements are found in Subpart M of Part 178. Based on the information in your letter, it appears that your material can be shipped as a limited quantity. Section 173.150 states that limited quantities of Class 3 (flammable liquids) may be packaged in non-specification combination packagings that conform to the general packaging requirements of subpart B of Part 173 and may not exceed 30 kg gross weight (66 pounds). Flammable liquids in Packing Group II must be packaged in inner packaging not over 1.0 L (0.3 gallon) net capacity each, packed in strong outer containers not to exceed 30 kg gross weight (66 pounds). Flammable liquids in Packing Group III must be packaged in inner packagings not over 5.0 L (1.3 gallons) net capacity each, packed in strong outer packagings not to exceed 30 kg gross weight (66 pounds). As defined in § 171.8, a strong outer container is the outermost enclosure which provides protection against the unintentional release of its contents under conditions normally incident to transportation. 173.202 020180#

Page 2Strong outer containers that are non-specification packagings do not have to be tested in accordance with the performance test requirements specified in Part 178. However, these packagings must conform to the general packaging requirements in § 173.24. I hope this information is helpful. If we can be of further assistance, do not hesitate to contact us. Sincerely, Delmer F. Billings Chief, Standards Development Office of Hazardous Materials Standards. ....#

Page 3The Clear Leader June 12. 2002 foster §173.202 Research and Special Program US Dept Of Iransportation Admin Packaging 400 7th Street Sw Office of Hazardous Material Safety 02-0180 Washington. D.C. 20590 To Whom It May Concern: Hazardous Material Information Line, On May 8, 2002, I spoke to Glen 1-800-467-4922,in and Cameron at the regards to requirements and standards for our cartons. liquid in corrugated rectangle We presently ship Pure Ethyl Alcohols, class 3 flammable our pint cartons do not meet and cartons. we are using corrugated The inner flaps on inserts to cover the open area. inserts a required DOT regulation? My question is, are these "No" and referred me to your organization so I might receive Glen and Cameron said this confirmation in writing fied. In August, we will be If this a DOT requirement, we would like our sending our cartons to be rencerti- and cartons labor costs. to be re-certified without the inserts to save money I would verifying this requirement within thirty days of receipt of this very much appreciate you contacting me by letter days, letter. pleace If: you cannot call me @ 1-800•456-1017 ext, 215 and let me know get a letter out to me within thirty us time to make the necessary arrangements. your thoughts. Then follow up with a letter. This will allow I appreciate your time in this matter. Sincerely, Lendo Whitton Traffic Manager Linda Whitton P.O. Box 339 • Shelbyville, KY 40066-0339 • 1-800-456-1017 • 1-502-633-0650 • Fax: 1-502-633-0685 http://www.aaper.com#