H.B. Fuller Company — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department 400 Seventh St., S.W. Washington, D.C. 20590 Research and Special Programs Administration JUN: 3 2004 Mr. Eugene J. Secor Ref. No. 04-0123 EHS/Transportation Specialist H.B. Fuller Company 31601 Research Park Drive Madison Heights, MI 48306 Dear Mr. Secor: This is in response to your May 5, 2004 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CPR Parts 171-180) applicable to package orientation arrows. Specifically, you ask whether the orientation arrows preprinted on your non-specification fiberboard boxes used for limited quantities of hazardous materials as shown in your accompanying photograph meet the requirements of § 172.312 of the HMR. The answer is no. Section 172.312 of the HMR requires each non-bulk combination package having inner packagings containing liquid hazardous materials be legibly marked, with package orientation markings that conform pictorially to the illustration shown in this section, on two opposite vertical sides of the package with the arrows pointing in the correct upright direction. Depicting a rectangular border around the arrows is optional. The package orientation arrows as displayed on your fiberboard boxes in your photograph do not conform pictorially to the illustration in § 172.312. I hope this information is helpful. sesh Chief, Standards Development Office of Hazardous Materials Standards 172.312 (a)E) 040123#

Page 2roster $172.312(92) Markings 04-0123 H.B. Fuller Company May 5, 2004 RSPA US DEPARTMENT OF TRANSPORTATION 400 SEVENTH STREET., SW STANDARDS DEVELOPMENT, DHM-11 WASHINGTON, DC 20590-0001 Re: Orientation Arrows Gentlemen: on non-specification fiberboard boxes used for Limited Quantities meet the requirements of 49 CFR During a recent internal DOT audit, the question arose over whether the "Orientation Arrows" preprinted 172.312(a)(2) which states "Legibly marked, with package orientation markings which conform pictorially to the illustration shown in this paragraph ... " A photograph is attached to illustrate the question. In this inches. These markings do appear on two opposite sides of the carton. I do not believe these meet the case there is no baseline on which the arrows stand and the arrows are spaced far apart, roughly 4 to 5 requirements of the regulation; as such I am asking for the Departments official position on this matter. helpful. I can be reached at 248-526-4783 during working hours. As always, the Departments assistance is much appreciated; an expeditious written reply would be most BEST REGARDS, Heve beer EUGENE J. SECOR EHS/TRANSPORTATION SPECIALIST HB FULLER COMPANY Madison Heights, MI 43306 31601 Research Park Drive FAX: 248-585-3699 Phone: 248-526-4783 e-mail: gene.secor@hbfuller.com File: DOT/Letters to DOT/Arrow Marking#

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