HB Fuller Company — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation 400 Seventh St., S.W. Washington, D.C. 20590 Research and Special Programs MAY 7 2003 Administration Mr. Gene Secor HB Fuller Company Ref. No. 02-0234 31601 Research Park Drive Madison Heights, MI 48071 Dear MI. Secor: documentation requirements under the International Air Transport This responds to your letter requesting clarification of the Association's Dangerous Goods Regulations (IATA DGR) • Specifically, you ask for this office's opinion of the IATA DGR shipper's declaration for dangerous goods and ask whether requirement to annotate the "Name and Title of Signatory" on the "Shipper" or "Shipping Clerk" are acceptable titles under 8.1.6.12 of the IATA DGR. I apologize for the delay in responding. and authorized in 49 CFR 171.11 as an alternative to compliance The regulations recognized by the Department of Transportation with 49 CFR requirements are Organization's Technical Instructions for the Safe Transport of the International Civil Aviation TI, there is no requirement to annotate a "Title" on a shipping Dangerous Goods by Air (ICAO TI). Under 5;4.1.6.1 of the ICAO paper in association with the certification. require that the certification be signed and dated by the The ICAO TI only shipper. Therefore, we suggest that you contact IATA directly regarding this matter at (514) 390-6770. Please contact us if we can be of further assistance. Sincerely, Thats z. Mittell Hattie I. Mitchell Chief, Office of Hazardous Materials Standards Regulatory Review and Reinvention 112.204 020234#

Page 2: SEP 85 2082 2:04 PM FR EFTEC MAD HTS MI248 585 3699 T0 12023663012 P .01 Stevens 8 1 71, 8 FAX 312.204 DATE: September 5, 2002 TO: Office of Hazardous Materials Standards, DHM-10 JATA FAX NUMBER: 202-366-3012 Shipping Papers FROM: GENE SECOR, HB FULLER CO 02-0234 PHONE: 248-526-4783 FAX: 248-585-3699 e-mail: gene.secor@hbfuller.com PAGES INCLUDING COVER SHEET: (2) MESSAGE: Gentlemen: I have a question on the signatory requirements required by the Shippers Declaration for Dangerous Goods for shipments by AIR. Specifically the question surrounds the definition of "Name/Title of Signatory". The name is self-evident but the definition of "Title" is not defined, per se, anywhere in the IATA regulations, 2002 Edition. At 8.1.4.1, it simply says "The declaration form must be signed by the shipper". At 8.1.6.12 it says "Enter the name and title of the person signing the Declaration" - Title undefined. We have recently been taken to task by Forwarders and/or carriers for not being (in their eyes) specific enough in the Title area. The personnel Ne have aiso used the term "Shipping Cierk" in efforts to be more vho actually do this work carry the Title in our organization "Shipper" definitive. These folks are the last to see/check the shipment prior to it's leaving the site. Is there something wrong with using the actual title of the person signing the document? Are forwarders/carriers imposing their own requirements in these instances even though not included in 2.9 - State and Operator Variations?#

Page 3SEP 05 2002 2:04 PM FR EFTEC MAD HTS MI248 585 3699 TO 12023663012 P.02 Your comments on the term "TITLE" for air shipments would be appreciated including, in the Department's opinion, whether we are complying with the regulations. Regards, Are tacor Gene Secor HB Fuller Company 31601 Research Park Drive Madison Heights, MI 48071 File: DOT/Letters and fax's ** TOTAL PAGE.02 **#