Packaging Corporation of America — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department Washington, D.C. 20590 400 Seventh St., S.W. Research and special Program! Administration OCT 22 2004 Mr. Michael Gilgenbach Ref. No. 04-0170 Packaging Corporation of America Technical and Development Center 2150 South Shaddle Avenue Mundelein, IL 60060 Dear Mr. Gilgenbach: This responds to your July 13, 2004 letter requesting clarification on the proper use of a package manufacturer's symbol or "M" number when marking UN specification packagings under 178.503(a) of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask whether your company, which produces corrugated boxes, an approval agency certifying compliance (e.g., third party testing facility), or a customer is required to have a symbol or "M" number. If your company does not accept responsibility for certifying a packaging and provides packagings to your customer who does accept responsibility for certifying the packaging, your company does not need an "M" number. I hope this answers your inquiry. Sincerely Chief, Standards Development Office of Hazardous Materials Standards 178.3 178.503 040170#

Page 2Boothe 7.- $118.3 $178.503 PCA Marking of lacksgings July 13, 2004 PACKAGING CORPORATION OF AMERICA 04-0170 Mr. Ed Mazzullo Director, Office of Hazardous Materials Standard U.S. DOT/RSPA (DHM-10) 400 7* Street SW Washington, DC 20590-001 Dear Mr. Mazzullo: I need to know the proper use of M numbers. I work for a company that produces corrugated boxes. Some of which are used for shipping hazardous materials. We do not number? Should we have an M number? If our customer is the Certifier of Record, certify the packages. It is done by third party labs. Should this third party lab have an M should they have an M number? We are never considered the "Manufacturer" would we need an M number? You may e-mail me at mgilgenbach@packagingcorp.com of fax a response to 847-482- 2100. Thank you for your help. Sincerely, Michael Gigentach Michael Gilgenbach Technical and Development Center • 250 South Shaddle Avenue • Mundelein, Illinois 60060 • Tel (847) 482-3000#