Totem Ocean Trailer Express, Inc. — Hazardous Materials Safety Interpretation

Page 1f Transportation .S. Departmen 400 Seventh Street, S.W. Washington, D.C. 20590 DEC 1 2005 Ms. Nancy Aird Reference No.: 05-0255 P. O. Box 4129 Totem Ocean Trailer Express, Inc. Federal Way, WA 98063-4129 Dear Ms. Aird: This responds to your letter concerning the use of certain abbreviations in the shipping paper description of a hazardous material under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Your questions are paraphrased and answered as follows: Q1. Are the only allowed definitions and abbreviations found in § 171.8? Al. The answer is no. In addition to § 171.8, definitions and abbreviations are found throughout the HMR. For example, abbreviations that may be used in a shipping paper description are found in Subpart B of Part 172 of the HMR. Q2. May the following commonly recognized words and abbreviations be used to describe the type of packing on a shipping paper or dangerous cargo manifest for vessel transportation? Barrel - bbl, can - cn, case - cs, carton -ctn, package - pkg, pail or tote. A2. Neither the HMR nor the IMDG Code specify terminology or criteria to describe the type or kind of packaging; hence, the terms are acceptable. Section 172.202 (a) (5) of the HMR 171.8 172.202(a)5) 050255#

Page 2Q3. Section 171.8 does not define the term "barrel." May "barrel" be used to describe a packaging type? A3. Yes. See A2. Also, the term "wooden barrel" is defined in § 171.8 of the HMR. I trust this satisfies your request. Sincerely, Hathe 2. Mitchel Hattie L. Mitchell Chief, Regulatory Review and Reinvention Office of Hazardous Materials Standards#

Page 3T TOTEM OCEAN TRAILER EXPRESS, INC. Corbin PO Box 4129 §172.201 (a)3) Federal Way, WA 98063-4129 $172:202 (a)l) Tel 253.449.8100 $ 176-30 (a)4 Fax 253.449.8225 October 03, 2005 www.totemocean.com Shipping Papers Mr. Edward T. Mazzullo 05-0265 Director, Office of Hazardous Materials Standards U.S. DOT/PHMSA (PHH-10) 400 7* Street S.W. Washington, D.C. 20590-0001 SUBJECT: LETTER OF INTERPRETATION Totem Ocean Trailer Express (TOTE) is a domestic maritime trailership shipping company out of Tacoma, WA and Anchorage, AK. TOTE is desirous of clarification on the correct abbreviations allowed for package types as prescribed by the following CFR 49 sections: CFR 49 SEC 172.201(a)(3) CFR 49 SEC 172.202(a)(6) CFR 49 SEC 176.30 (a)(4) TOTE has been instructed through our hazardous recertification training that only Definitions and Abbreviations found in CFR 49 SEC171.8 are allowed on shipping papers and vessel dangerous cargo manifests. TOTE is using HM 215 G. TOTE receives Roll-On/Roll-Off trailer and container shipments from shippers and consolidators using various modes of transportation nation and world wide. They use various common words and abbreviations not found in the CFR 49 SEC 171.8., for example: BARREL (BBL), CAN (CN), CASE (CS), CARTON (CTN), PACKAGE (PKG), PAIL, and AND TOTE. CFR 49 SEC 172.201(a)(3) states, "Unless it is specifically authorized or required in this subchapter, the required shipping description may not contain any code or abbreviation." At the same time CFR 49 SEC 172.202(a)(6) indicates, "Abbreviations may be used for indicating packaging types ... provided the abbreviations are commonly accepted and recognizable. Additionally, CFR 49 SEC 176.30 (a) (4) reads "The number and description of packages (barrels, drums, cylinders, boxes, etc) and gross#

Page 4TOTEM OCEAN TRAILER EXPRESS, INC. PO Box 4129 E® Federal Way, WA 98063-4129 Tel 253.449-8100 Fax 253.449.8225 weight for each type of packaging." Please note that "BARgaoom included in the definitions outlined in CFR 49 171.8." TOTE requests clarification on the following questions for ocean transportation. 1) Are the only allowed definitions and abbreviations found in CFR 49 SEC 171.8? 2) Are the below named (common and recognizable) words and abbreviations allowable on hazardous shipping papers and dangerous cargo manifests? For example, shippers and consolidations use barrel (bbl), can (cn), case (cs), carton (ctn), package (pkg), pail and tote. 3) Is Barrels (BBL) an allowed word and abbreviation? Barrels is not allowed by CFR 49 171.8, but is referenced as an example in CFR 49 SEC176.30 (a)(4). It is TOTE s interpretation that Barrels may be used. TOTE will use your official LETTER OF INTERPRETATION on these issues to educate and inform all of its shippers. Thank you for your review and response to our questions. Sincerely, Haney fiel Nancy Aird TOTE DOC/HAZARDOUS Cc. Matt Devenere - TOTE John Armstrong - TOTE Paul Den - TOTE Bill King - TOTE#