Unilever Home & Personal Care - USA — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department JAN 28 2004 400 Seventh St., S.W. Washington, D.C. 20590 Special Programs Research and Administration Mis. Teresa L. Medley Reference No.: 03-0291 Director, Regulatory Affairs Unilever Home & Personal Care - USA 75 Merritt Boulevard Trumbull, CT 06611 Dear Ms. Medley: This is in response to your letter requesting clarification of the marking requirements for packagings containing limited quantities and ORM-D materials under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). As you are aware, in RSPA Docket HM-215E (68 FR 44991) we added a new section, and may be used in lieu of the marking requirements prescribed in § 172.301(a). Section 172.315 does not apply to packagings containing ORM-D materials. The marking requirements in § 172.316 that apply to ORM-D materials remain unchanged. I trust this satisfies your inquiry. Sincerely, Hothe z. Mitchell Hattie L. Mitchell Chief, Regulatory Review and Reinvention Office of Hazardous Materials Standards 3/6 172.: 030291#

Page 2Unilever Corbin $112.316 November 14, 2003 Markings Research and Special Programs Administration U.S. Department of Transportation 03-0291 Office of Hazardous Materials Standards 400 Seventh Street, SW Washington, DC 20590 Attention: Mr. Ed Mazzullo Re: New "Limited Quantity" Marking This letter is written to request clarification of the applicability of the new "limited within a square-on-point border with a line width of at least 2mm. allows the shipper to use either the new marking, or to mark limited quantity packages as While HM-215E proposed a mandatory marking for all limited quantities, the final rule "Consumer Commodities": currently required by the HMR. The current rule at 49 CER 172.316 requires that be marked on at least one side or end with the ORM-D designation immediately following or below the proper shipping name of the material. Moreover, "Consumer Commodity" materials are not further identified by a UN/NA ID Number (49 CFR 172.101 - Hazardous Materials Table). Thus, logic would indicatę the UN Identification number is not required for Consumer Commodity shipments; however, formal clarification on this pointed would be appreciated. Sincerely, Jersed molley Teresa L. Medley Director, Regulatory Affairs CC: Rajiv Tata, UNUS Legal Unilever Home & Personal Care - USA 75 Merritt Bouleyard • Trumbull, CT 0661. telephone (203) 377-8300#