ArthurP. Hancock — Hazardous Materials Safety Interpretation

Page 1.:. Washington. D.C. 400 Seventh Street, S.W. 20590 Research and Special Programs Administration NOV 2 3 1998 Arthur P. Hancock Ref. No.02-0285 42 Gorse Road Cookham, Berks SL6 9LL England Dear Mr. Hancock: This is in response to your facsimile of November 16, 1998, concerning a new requirement for limited quantities of dangerous goods introduced into the European road and rail regulations for transporting dangerous goods (ADR/RID). The new requirements (e.g., marginal 2301a of the ADR), which become effective on January 1, 1999, are for a diamond shaped label to appear on packages of limited quantities of dangerous goods. The label is to bear the United Nations number of the item of dangerous goods contained in the package or the letters "LQ" when more than one item of dangerous goods is in the package. You asked whether packages so labeled would be acceptable for transport in the United States. We consider packages so labeled to be unacceptable for transport in the United States. The US Hazardous Materials Regulations (HMR) in Title 49 of the Code of Federal Regulations in prescribed" by the HMR. In our opinion, the labeling required by the new ADR/RID requirements 172.401(b) prohibits labeling "which by its color, design, or shape could be confused with a label could be so confused. Therefore, such labeling is prohibited from use in the United States. Sincerely, This Libe Frits Wybenga, International Standards Coordinator for Hazardous Materials Safety 020285#

Page 2% 10/11/1000 11:40 440102052G153 DANGEROUDGNDGAGENCY ГАСЕ 01 FAX From: Arthur Hancock Phone/fax 01628 526153 42 Gorse Road, Conkham, Berks SL6 9LL England on behalf of AISE To: Mi.F. Wybenga JS Dept.of Transportation Fax: 00 1 202 366 5713 Datc: 16th November 1998 Number of pages (inclusive) ONE Subject: Dangerous Goods in Limited Quantities Limited Quantities must be marked with the I/N Numbers) in a diamond shaped As you are aware, RIJAJ have introduced a requirement that packages containing outline measuring 100mm x 100mm. ubjection to this marking method for goods shipped by sea or air. According to my assessment and advice given by UK comperent authorities there is no Howovcr, I am informed by a shipper to the USA that he las been told that such a then industry is faced with having to change package markings according lo the final marking would not be permitted for goods distributed with the USA. If this is true Chapter 3.4. distribution which is one of the problems AISE wishes to overcome in reviewing UN Could you please let me have your advice about this. Yours sincerely. Har A.P. Hancock NOV 23 1998#