"K" Line America, Inc. — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department 400 Seventh St., S.W. Washington, D.C. 20590 Research and Special Programs Administration MAR 2 4 2004 Lisa Stone "K" Line America, Inc. Ref. No. 04-0006 Richmond, VA 8730 Stony Point Parkway, Suite 300 23235 Dear Ms. Stone: This is in response to your letter dated January 8, 2004, packages on shipping papers in accordance with the Hazardous regarding the requirement to indicate the number and type of Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically you ask whether you may describe your intermediate bulk container as "Super Sack" on a shipping paper. number and type of packages must be indicated. The answer is yes. Section 172.202 (a) (6) specifies that the packages may be indicated by the description and by packaging The type of specification number when applicable. I hope this satisfies your request. Sincerely John A Standards Development Ga Chief office of Hazardous Materials Standards 172.203(97(6) 040006#

Page 2: Request for Letter of Interpretation Page 1 of 1 BAH INFOCNTR 5/72.202101(6) From: . Stone, Lisa (KAM.RIC) Sent: Thursday, January 08, 2004 3:15 PM Shipping Papers To: INFOCNTR Subject: Request for Letter of Interpretation 04-0006 It would be greatly appreciated if a letter of interpretation could be sent to clarify the following issue: is not decribed spesicaly in i Amendment 1, Pa 4, nor 49CFR -Past 178 or word the escripton te more appropriate as Flexible IBC or IBC08? UN specifications: 13H1 Thank you for your clarification in this matter. Best Regards "K" Line America, Inc. Lisa Stone 8730 Stony Point Parkway, Suite 300 ald (PH) 804-560-2089 Richmond, VA 23235 lisa.stone@us.kline.com 1/9/04#