Eastman Chemical Company — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation MAY 24 2004 400 Seventh St., S.W. Washington, D.C. 20590 Research and Special Programs Administration Ms. Kimberly D. Glover-Brown Ref. No. 04-0018 Eastman Chemical Company 2801 Lynwood Road Lynwood, CA 90262 Dear Ms. Glover-Brown: This is in response to your January 23, 2004 letter requesting clarification regarding the marking pecifically, you ask whether a tag showing the retest date affixed near the serial number plate o fIBCs under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) an IBC would comply with the HMR. The answer is no. Section 180.352(e) states that the date of the most recent periodic retest must be marked as provided in § 178.703(b). Section 178.703(b)(2) states, in part, that for each metal IBC, the marking must be included on a metal corrosion resistant-plate. Therefore, a tag showing the retest date affixed near the serial number plate of an IBC does not conform to the above referenced requirements. I hope this information is helpful. If you have additional questions, please do not hesitate to contact this office. Sincerely, Hotter mikele Hattie L. Mitchell, Chief Regulatory Review and Reinvention Office of Hazardous Materials Standards 040018 178.703#

Page 2178.005 Bets INFOCNTR Sent: From: Glover-Brown, Kimberly D - Eastman [kimbrown@eastman.com] To: Thursday, January 22, 2004 4:21 PM IBC Subject: Cc: INFOCNTR RE: Recertification dates on IBCs Truelsen, Barbara A - Eastman; Sutkowski, Richard - Eastman 04-0018 Picture 058.jpg date on our IBC'S. The above picture shows how we are currently marking the recertification compliance but there is a question, hence the need for clarification. According to the 49 CFR we believe we are in Please forward a formal letter of clarification to: Kimberly Glover-Brown 2801 Lynwood Road Eastman Chemical Company USA Lynwood, CA 90262 (310) 884-5522 Thank you very much for your assistance. From: INFOCNTR [mailto:Infocntr@rspa.dot.gov] ~ -Original Message- To: Glover-Brown, Sent: Thursday, January 22, 2004 10:47 AM Subject: RE: Recertification dates on IBCs Kimberly D - Eastman Dear Ms. Glover-Brown, we have received your inquiry about the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). The HMR are available at the following URL: provided in § 178.703(b). Section 178.703(b) specifies that each IBC Section 180.352 (e) requires the most recent test date to be be marked as must be marked in a place near the manufacturer markings. Center is staffed with regulatory specialists who can quickly answer If you require further assistance, our Hazardous Materials Information Center is open Monday through Friday, 9 am questions by phone. Please do not hesitate to call; as the Information 467-4922 pm E.S.T. at (800) or (202) 366-4488. Sincerely, Kevin Leary, Hazardous Materials Specialist Formal An e-mail response from this office is considered informal guidance. http://hazmat.dot.gov/infocent.htm guidance may be requested in accordance with 49 CFR 105.20. From: Glover-Brown, Kimberly D - Eastman [mailto:kimbrown@eastman.com] -----Original Message----- 1#

Page 3TO: INFOCNTR Sent: Wednesday, January 21, 2004 1:07 PM Importance: High Subject: FW: Recertification dates on IBCs From: -----Original Message--- Sent: Wednesday, Glover-Brown, Kimberly D - Eastman To: 'infocntr@rispa.dot.gov' January 21, 2004 10:05 AM Subject: Importance: FW: Recertification dates on IBCs -----Original Message-- Wednesday, Glover-Brown, Kimberly D - Eastman " infocenter@rispa.dot.gov' January 21, Subject: FW: Recertification dates on IBCs From: --Original Message--- Sent: Wednesday, January 21, 2004 9:52 AM Glover-Brown, Kimberly D - Eastman Subject: Recertification dates on IBCs To: 'infocentr@rispa.dot.gov' > I have just finished a telephone conversation with the info center of > DOT and they advised to send this email to obtain a written response to the following question. cecertification date near the Serial number plate be sufficient for Would an affixed tag showing the fine according to 180 subpart D of the 49CFR, quality and maintenance OT? I was told by the operator of the info center that it would be written response. Thank you in advance. of Intermediate Bulk Containers. However I think it is best to have a > > Kimberly Glover-Brown > 2801 Lynwood Road Eastman Chemical USA Lynwood, CA 90262 > (310) 884-5522#

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