3M General Office — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Deparment 400 Seventh St., S.W. Research and Washington, D.C. 20590 Special Programs Administration MAR 2 1 2003 Mr. Raymond T. Duzynski Regulatory Analyst Ref. No. 02-0201 3M General Office 3M Center St. Paul, MN 55144-1000 Dear Mr. Duzynski: This responds to your July 23, 2002 letter requesting an interpretation of the Hazardous Materials Regulations (HIMR; 49 CFR Parts 171-180) applicable to shipping papers. Specifically you ask if it is necessary to remove the letters "RO" and the name of the hazardous substance(s) from the shipping longer meets the definition of a hazardous substance and the phrase "RESIDUE: Last Contained ***» paper for the return trip of a bulk package other than a tank car when the residue in the package no does not appear on the shipping paper before the basic description. The answer is no. In accordance with § 172.203(e)(2), the description on the shipping paper for a tank car containing the residue of a hazardous material must include the phrase "Residue: Last Contained ***" before the basic description. If, when fully loaded, the correct shipping description for the material in the tank car required the letters "RQ" to be included, the letters "RO" are not required to be removed from the shipping paper description when the residue in the tank car no longer meets the definition of a hazardous substance. I hope this information is helpful. If we can be of further assistance, do not hesitate to contact us. Sincerely, Shan Hills Delmer F. Billings Chief, Standards Development Office of Hazardous Materials Standards 172.203 (e)(2) 020201#

Page 23M General Office St. Paul, MN 55144-1000 3M Center 651 733 1110 Foster $172.203 (e)(z) July 23, 2002 Shipping Papers ЗМ Mr. Edward T. Mazzullo 82-0201 DHM-10 (Room 8422) Director, Office of Hazardous Materials Standards U.S. Department of Transportation Office of Hazardous Materials Standards Research and Special Programs Administration 400 Seventh Street, SW Washington, DC 20590-0001 Subject: Interpretation Letter Request Dear Mr. Mazzullo: In the enclosed DOT Letter of Interpretation (Reference No. 01-0137) dated material meets the definition of a hazardous substance under Section 171.8. August 16, 2001, it states the letters "RQ" may only be entered on the shipping paper if a In the enclosed DOT Letter of Interpretation (Reference No. 01-0210) dated January 18, 2002, it states that the letters "RQ" are not required to be removed from the hazardous substance. The tank car discussed in this DOT Letter of Interpretation originally shipping paper when the residue in the tank car no longer meets the definition of a contained an "RQ" of ethylbenzene and the shipping paper for return trip of the tank car includes the phrase "Residue: Last Contained ***" before the basic description as required per Section 172.203(e)(2). Based on this information, could you comment on whether it is necessary to remove the letters "RQ" and the name of the hazardous substance(s) from the shipping paper for the return trip of bulk package other than a tank car (c.g., portable tank) when the residue in the package no longer meets the definition of a hazardous substance and the phrase "Residue: Last Contained ***" does not appear on the shipping paper before the basic description. 651-733-9042. If you have any questions or need additional information, please contact me on Sincerely, Raymond T. Duzynski Regulatory Analyst Enclosures#