Sandia National Laboratories — Hazardous Materials Safety Interpretation

Page 1U.S.Department 400 Seventh Street, S.W. of Transportation Washington, D.C. 20590 Research and Administration Special Programs NOV - 8 2002 Mr. Roland M. Kelley Sandia National Laboratories Ref. No. 02-0265 P.O. Box 5800 MS 1120 Albuquerque, NM 87185 Dear Mr. Kelley: This is in response to your facsimile dated October 1; 2002, and subsequent telephone conversation with Sandra Webb, of my staff, requesting clarification of the Hazardous Materials Regulations (HMR, 49 CR Parts 171-180). Specifically, you asked whether the "UN" symbol you submitted for. our review is acceptable as a marking on a UN standard packaging. We apologize for any misinformation you received from this office: The markings as shown on the examples, enclosed with your letter, do not conform with the requirements in § 178.503. As provided in § 178.503; a packaging which meets the UN standard and has been tested in accordance with Subpart L of Part 178, of the HMR, must be marked with the UN symbol as illustrated in 49 CFR § 178: 503(e)(1). The example symbol you submitted is not displayed in a solid circle as illustrated in $ 178.503(e)(1), thus not acceptable. I hope this information is helpful. Sincerely, Delma 7Bilf0 Delmer F. Billings Chief, Standards Development Office of Hazardous Materials Standards 178.503 020265 40926313997#

Page 2LOGISTICS RISK MGMT Fax:505-844-5013 Oct 1 2002 15:27 P. 02 Sandia National Laboratories Oporato to thalias opporati or Eners by Sandia National Laboratories Albuquerque, New Mexico 87185-1453 PO Box 5800, MS 1120 Albuquerque, NM 87185 Webb October 1, 2002 $178.503 (e)C) Mr. Edward T. Mazzullo, Director Marking DHM -10 U.S. Department of Transportation 02 - 0265 Research and Special Programs Administration 400 Seventh Street SW Office of Hazardous Materials Standards Washington, D.C. 20590 RE: Interpretation of 178,503 (e) (1) Dear Mr. Mazzullo: stating, "The following are examples of symbols and required markings:" and shows an On October 1, 2002, I spoke with your organization by phone about Tile 49 Part 178.503 (e)(1) example of a circle (solid line not broken) with the letters "u" and "n" located inside the circle. the fact that stenciling is a very common way of marking in industry and requires bridges thru As the regulation reads the circle must appear as shown (solid line). The question is based on the solid fines to hold the letters inside the circle. Two examples of "un" symbols currently in use today were sent and reviewed by your office. The decision was that the two examples that were reviewed by your office. were acceptable. Wé have attached the two examples of "un" symbols currently in use today At this time Sandia National Laboratories requests the confirmation of your verbal interpretation in writing. Thank you for your quick responses in this matter. Should you have any further questions please contact me at 505-845-7337. Sincerely, Potend MKellay Roland M. Kelley Packaging Consultant Attachment Exceptional Service in the National Interest#

Page 3LOGISTICS RISK MGMT Fax:505-844-5013 Oct 1 2002 15:27 P. 03 examole z#

Page 4LOGISTICS RISK MGMT Fax: 505-844-5013 Oct 1 2002 15:27 P.04 n Example #2#