Mallinckrodt Baker, Inc. — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Washington, D.C. 20590 400 Seventh Street, S.W. Pipeline and Administration Hazardous Materials Safety MAY 6 2005 Ms. Dianna F. Lee Ref. No. 05-0062 600 N. Broad Street Mallinckrodt Baker, Inc. Phillipsburg, NJ 08865 Dear Ms. Lee: This responds to your November 3, 2004 letter and March 18, 2005 fax requesting internationally under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171- clarification on the labeling requirements for 'Methanol' when shipped domestically and 180). Specifically, you ask whether it is permissible to label the package in compliance with international requirements when shipped domestically only. The answer is yes. As your letter notes, the Hazardous Materials Table (HMT) includes two entries for methanol, one for international transportation and one for domestic transportation. The two entries are identical, except that the international entry requires a subsidiary hazard Division 6.1 label, and the domestic entry does not. In accordance with § 172.101(b)(3) and (b)(5), you may use either the international or domestic entry in the HMT for domestic transportation of metharol. I hope this answers your inquiry. C Chief, Standards Development Office of Hazardous Materials Standards 172.101 172.419 050062#

Page 2MAR. 18'2005 11:06 9088599411 MALBAKER QUALITY DEFT #0650 P. 002/003 Boothe tyco 3172.101 222 Rod School Lane Mallincinodt Baker, Inc. Phillipsburg, NJ 08865 Specialty Products 3M2 119 Fax: 908-859-9411 Tal: 908-859-2151 Mallinckrodt Baker Label ing 05-0062 Mr. Edward T. Mazzullo Director, Office of Hazardous Materials Standards U.S. DOT/PHMSA (DHM-10) 400 7th Street S.W. Washington, D.C. 20590-0001 November 3, 2004 Dear Mr. Mazzullo, This letter is a request for a letter of interpretation regarding a hazardous material, methanol. To give you a brief overview of the situation, our company sells methanol as a product, international shipments. We are currently assessing the possibility of consolidating the and traditionally have been packaging and labeling them separately for domestic and toxic labels to both domestically and interationally shipped packages. two and just use the international classification, and affixing both the flammable and The current 49 CFR specifies in the Hazardous Materials Table (172.101) that for a letter "D) and one for international (denoted by a letter "'") shipping purposes. The Vethanol, UN1230, PGIl, there exists two entries, namely one for domestic (denoted by two entries are identical except for the labeling codes required. International shipping requires both a flammable label (3) and a toxic label (6.1) in order to meet the requirements for hazard classes. Domestic shipping, however, only requires the flammable label (3), and there is no mention of toxicity hazards associated with the chemical. According to section 172.101(b)(5), "The letter "'" identifies proper shipping names which are appropriate for describing materials in international transportation. An involved." Mv interpretation of this is that although we may choose to use the domestic alternate proper shipping name may be se ected when only domestic transportation is classification with only the flammable label and hazard class 3 requirement for methanol, we will not be out of compliance if we choose to disclose the toxicity hazard and classify our product (methanol) as class 3, with a subsidiary hazard class of 6.1, which requires both the flammable and toxic labels for domestic shipping only purposes.#

Page 3MAR. 18'2005 11:06 9088599411 MALBAKER QUALITY DEPT #0650 P.003/003 I would appreciate it if you can please rep y back with an official interpretation from the and out of compliance to affix both flammable(3) and toxic(6.1) labels on a package of hazmat administration regarding this issue: as to whether or not we would be incorrect methanol shipped domestically only. The response can be forwarded to the below address, and should you have any questions, please feel free contact me at the number also provided below. Mallinckrodt Baker, Inc. 600 N. Broad Street Phillipsburg, NJ 08865 (908)859-2151 ext. 9764 Once again, thank you in advance for you help and clarification in this matter, and I look forward to hearing from you. Sincerely, Dia L. Le Dianna F. Lee Quality Information Acministrator#