Tyco Healthcare/Mallinckrod — Hazardous Materials Safety Interpretation

Page 1I.S. Departmer f Transportatio FEB 28 2005 Washington, D.C. 20590 400 Seventh St., S.W. Special Programs Research and Administration Ms. April Chance Ref. No. 05-0005 Manager, Radiological Affairs Tyco Healthcare/Mallinckrodt 675 McDonald Blvd Hazzelwood, MO 63042 Dear Ms. Chance: This is in response to your letter dated January 5, 2005, regarding the shipper's certification prescribed in § 172.204 of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you request clarification on the signature requirement in § 172.204(d). Your questions are paraphrased and answered below. Q1: Is it acceptable to use a rubber stamped name with an adjacent signature or initials to fulfill the signature requirements in § 172.204(d)? Al: The answer is yes. The certification must be legibly signed by a principal, officer, partner, or employee of the shipper or his agent; and (2) may be legibly signed manually, by typewriter, or by other mechanical means. The use of a rubber stamp to produce a signature would satisfy this requirement. Q2: Is it acceptable to use a signature page that cross-references printed names with signatures, which would remain at the facility (i.e. would not accompany the shipping paper), to fulfill the shipping paper requirements in § 172.204(d)? A2: The answer is no. By providing a certified shipping paper the person who offers a hazardous material for transportation certifies that the material is offered for transportation in accordance with the HMR. The required shipping paper must contain the shipping description, a certification statement (see § 172.204(a)(1) or (a)(2)), and an authorized signature (see A1). I hope this satisfies your request. Sincerely, TonnA Cale Chief, Standards Development Office of Hazardous Materials Standards 172.204(1) 050005#

Page 2tyco Mallinckrodt /nc. 675 McDonnell Boulevard Healthcare P.O. Box 5840 St. Louis, MO 63134 Mallinckrodt www.mallinckrodt.com Tele: 314 654-2000 BAH January 5, 2005 $172.204 (d) U.S. Department of Transportation Shipping Papers esearch and Special Programs Administratio ffice of Hazardous Materials Standard 05-0005 Attn: DHM-10 400 7' Street SW Washington, DC 20590-0001 RE: Interpretation of 49 CFR §172.204(d) To Whom It May Concern: Pursuant to the provisions of 49 CFR §105.20(a), I am requesting an interpretation of the requirement for a legible signature on the shipping paper, found in §172.204(d). I would also like to propose two methods for achieving compliance. First, a signature page that cross references printed names with signatures. This page would stay at the facility, i.e., would not accompany the shipping paper. The second alternative is a rubber stamped name with adjacent signature or initials. Thank you in advance for your prompt attention in this matter. If you have questions, please do not hesitate to contact me at (314) 654-7960 or (314) 267-9140. Tacerely, Alchance April C. Chance, CHI Manager, Radiological Affairs Tyco Healthcare/Mallinckrodt CC: K. Yoder#