Dangerous Goods Advisory — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department Washington, D.C. 20590 400 Seventh Street, S.W. Hazardous Materials Safety Pipeline and Administration OCT 1 1 2005 Mr. Alan I. Roberts President Ref. No.: 04-0261 Dangerous Goods Advisory Council Washington, DC 20005-5484 1100 H Street NW, Suite 740 Dear Mr. Roberts: This is in response to your November 8, 2004 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Please accept my apology for our delay in responding and any inconvenience this may have caused. Specifically you ask this office to reconsider its previous interpretation regarding submitted examples of stenciled United Nations (UN) symbol markings (Ref. No.: 02-0265). The markings as shown in the examples from the letter from Mr. Roland M. Kelley of Sandia National Laboratories do not conform to the requirements in § 178.503. However, a stencil with the minimum gap necessary to support the center of the circle with the letters "u" and "n" is authorized to apply the UN symbol to the packaging. We intend to clarify this issue in a future rulemaking. I hope this information is helpful. If you have further questions, please do not hesitate to intact this office. Hattie L. Mitchell Chief, Office of Hazardous Materials Standards Regulatory Review and Reinvention Cc: Mr. Roland M. Kelley, Sandia National Laboratories, P.O. Box 5800 MS 1120, Albuquerque, NM 871-5 ITH MINI 178.503 040261#

Page 2-. Dangerous Goods Advisory Council DGAC Suite 740 • HStreet Street NW Washington DC 20005 • 202/289-4550 • Fax 202/289-4074 • www.dgac.org Pollack November 8, 2004 $178.503 Office of Hazardous Materials Standards (DHM-10) Mr. Edward Mazzullo, Director Marking of Packagings Research and Special Programs Administration U.S. Department of Transportation 04. 0261 400 Seventh St., SW Washington, DC 20590-0001 symbol marking on packagings Re: RSPA letter of interpretation dated November 8, 2002 clarifying the UN Dear Mr. Mazzullo, In response to an enquiry from Sandia National Laboratories, RSPA issued a letter of small gaps in the circle is not acceptable. The basis of the decision appears to be that the interpretation (copy attached) stating that a stenciled version of the UN symbol containing. circle must be completely solid, as illustrated in § 178.503(e). For various practical conșiderations, we ask that you reconsider this decision. There are several techniques packaging manufacturers can employ to produce a durable: symbol and other required information. Of course, by its nature, a stencil leaves small gaps mark on a UN certified packaging. A rather common method is to use a stencil for the UN in certain symbols, letters and numbers. Viewed from a short distance away, however, information displayed. To achieve a solid circle requires a second method to apply the these gaps are hardly discernible and the overall effect is complete legibility of the worse, results in a less clear marking. Controlling a two-step process with various inks symbol, often a rubber stamp. This action incurs additional expense and, to make matters introduces more variability, which many times results in a smeared image. Stamping on a rounded surface contributes to the problem. If a stenciled image is legible to start with and the packaging manufacturer then goes f the regulation." does this achieve any useful purpose? For this reason we ask that yo trough a more expensive process to achieve a solid, but blurred, image to meet the "lette reconsider your earlier decision and issue a revised interpretation that permits the use of stenciling for the circle surrounding the UN symbol. Sincerely, Alan I. Roberts President • DGAC is a leading international membership organization representing all aspects of the hazardous materials/dangerous goods trarisportation industry. + • DAC is a leading intemational membership organization representing all aspects of the hazardous materials/dangerous goods transportation industry. •#