Transport Management Group — Hazardous Materials Safety Interpretation

Page 1400 Seventh Street, S.W. Washington, D.C. 20590 Pipeline and Administration Hazardous Materials Safety MAY - 3 2006 Mr. Timothy Wagner President Ref. No. 06-0016 15400 Pearl Road #236 Transport Management Group Strongsville, OH 44136 Dear Mr. Wagner: This responds to your January 17, 2006 letter requesting clarification concerning the use combination packaging containing a plastic inner bottle without retesting as a combination packaging. A UN 1A2 steel drum that is an authorized single packaging may contain inner adversely impact the level of performance of the packaging. This configuration would receptacles that are compatible with the lading as long as the inner receptacles would not comply with the HMR and the ICAO Technical Instructions. The packaging would remain marked as a single packaging. I hope this information is helpful. Please contact us if you require additional assistance. Sincerely, Chief, Standards Development Office of Hazardous Materials Standards 173.24a(613) 060016#

Page 2Learu tmg! §113.24a (6) (3) TRANSPORTATION MANAGEMENT GROUP, INC. Specializing in Hazardous Material Training Packagings January 17, 2006 06 - 0016 International Standards Coordination Office 400 7* Street Southwest DHM-5 US Department of Transportation Washington DC 20590 Dear Mr. Mazzulle: We encounter a problem regarding our UN packaging for a plastic can, which has a metal developed for this can to enable the cartoned product to pass the pressure test required for friction lid. According to our research, there will never be an armlock/ringlock air freight. Therefore, we have been putting the plastic can into a five gallon UN1A2, as the "outer" JN1A2 is not marked as a "combination" containing the "S" in the UN Specification ›f a combination packaging, with absorbent material, when it is shipped via air. This Marking. This method of packaging is authorized under 49 CFR 173.24a (b) 3, which states "A single or composite non-bulk packaging which is tested and marked for liquid considered a "solid." Due to the existing provision in 49 CFR, our packaging is compliant for domestic shipments. The problem occurs when it is an ICAO/IATA export shipment. We are applying for a formal approval/addition of the same provision in 49 CFR, to the ICAO would also further the harmonization effort. ICAO Technical instructions, citing justification as allowable in 49CFR. An approval in your forth coming reply. Let me know if you have any questions, or need additional information. I look forward to Regards, im. thy way an President Timothy Wagner 15400 Pearl Road #236 Transportation Management Group, Inc. Strongsville, Ohio 44136 866.572.8644 P.O. Box 360458 Strongsville, OH 44136-9998 www.tmgihazmat.com • • PHONE 440.572.5002 • TOLL FREE 866.572.8644 • FAX 440.572.0876 email: sales@tmgihazmat.com#