Sandia National Laboratories — Hazardous Materials Safety Interpretation

Page 1or ransominon Washington, D.C. 20590 400 Seventh St., S.W. Special Programs Research and Administration OGT 16. 2002 Roland M. Kelley Packaging Consultant Ref No. 02-0238 Sandia National Laboratories .O. Box 5800, MS 112 lbuquerque, NM 8718: .:a. Dear Mr. Kelley: This is in response to your September 3; 2002 letter, requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to marking requirements on the side of steel drums. Specifically, you question the current validity of Interpretation letter: dated August 23, 1993 and addressed to Evans Industries, Inc. stating that the United Nations symbol is required for any additional replication of markings other than embossed. As provided in § 178.503, a packaging conforming to a UN standard must be marked with the United Nations symbol as illustrated in paragraph (e)(1) of this section. The letters, "UN" may be applied in place of the symbol for embossed metal receptacles. Any additional replication of the required UN marking through other means (e.g. silk screening or stenciling) must include the UN symbol rather than the letters "UN". I hope this information is helpful. If we can be of further assistance, do not hesitate to contact us. Sincerely, Die FiStfi Delmer F. Billings Chief, Standards Development Office of Hazardous Materials Standards /78.503 020238#

Page 2Sandia National Laboratories sir: Operated for the U.S. Department of Energy by Sandia Corporation Sandia National Laboratories Albuquerque, New Mexico 87185-1453 PO Box 5800, MS 1120 Albuquerque, NM 87185 Foster $178.503(X1) September 3, 2002 Marking DHM -11 Ms. Sandra Webb, Transportation Reg. Specialist 02-0238 U. S. Department of Transportation Research and Special Programs Administration Office of Hazardous Materials Standards 400 Seventh Street SW Washington, D.C. 20590 RE: Interpretation of 178.503 (a) (1) Dear Ms. Webb: phone requesting clarification of 178.503 in reference to the additional marking reqüirement on On August 28 and 29, 2002, I spoke to you and Mr. Arthur Pollack, on separate occasiöns by the sides of steel drums. The interpretation letter dated August 23,1993, and addressed to replication of markings other than embossed. During our discussions it was confirmed that the Evans Industries, Inc., (07238.pdf) stated that the UN symbol is required for any additional clarification is still valid and that the regulations still require that "Any additional replication of the required UN marking through other means (e.g. silk screening or stenciling) must include the UN symbol rather than the letters "UN"* letter dated August 23,1993, and addressed to Evans Industries, Inc., is still valid and binding. At this time Sandia National Laboratories requests confirmation in writing that the interpretation Thank you for your quick responses in this matter. Should you have any further questions please contact me at 850-547-2122 or 505-845-7337. Sincerely, She Kelly, Roland M. Kelley Packaging Consultant Attachment Exceptional Service in the National Interest#