U.S. Coast Guard CITAT — Hazardous Materials Safety Interpretation

Page 1or ansportione Washirigton, D.C. 20590 400 Seventh Street, S.W. Pipeline and JUN 16 2006 Administration Hazardous Materials Safety Mr. Steven T. Webb Reference No. 06-0022 U.S. Coast Guard CITAT 6500 South Macarthur Boulevard Oklahoma City, OK 73169 Dear Mr. Webb: This is in response to your request for a clarification of the marking requirements for Q1. Is the marking the International Maritime Dangerous Goods Code (IMDG) requires number for the material in a white square-on-point diamond, unless excepted under for limited quantity shipments under Section 3.4.5.1.2, i.e., the UN identification Section 3.4.7, the same as that required for limited quantity shipments under § 172.315 of the HMR? Al. Yes. As specified in § 172.315, except for transportation by aircraft, marking the ackage with the identification number inside a white square-on-poin onfiguration identifies the material as a limited quantity and fulfills th requirements of § 172.301(a)(1). If a shipper uses this method to identify packages shipping name, technical name, hazardous substance name(s) or "RQ" on the outer containing limited quantities, the shipper is not required to mark the proper package. Q2. If the shipper marks the package with the proper shipping name and UN identification within the white square-on-point diamond? identification number, is the shipper also required to mark the package with the UN 172.315 060022#

Page 2A2. No. If a shipper does not use the UN identification within the "white square-on- with marking requirements for non-bulk packages prescribed in § 172.301, and point diamond" exception, the outer package for a limited quantity must comply other applicable requirements in 49 CFR Part 172, Subpart D, for the hazard classes) contained within the package. I hope this information is helpful. Sincerely, Hattie L. Mitchell, Chief Regulatory Review and Reinvention Office of Hazardous Materials Standards#

Page 3Nickels, Matthew <PHMSA> From: Sent Steven. T.Webb@USCG.MIL Monday, January 30, 2006 4:26 PM Edmonson Subject: Information Center Comments/Questions INFOCNTR <PHMSA> $172.315 Below is the result of your feedback form. Steven Webb Free fres it i ready January 30: 20 al: 03028 06-3022 It was submitted by Email: Steven. T. Webb@USCG. MIL Name: Steven Webb Communications Hazardous Materials Table, Special Provisions, Hazardous Materials Organization: United States Coast Guard CITAT Street: 6500 S. Macarthur Blva City: Oklahoma City State: Oklahoma Zip Code: 73169 Phone: 405-954-4425 Fax: 405-954-9217 Comments: Dir Sir or Madam, I am writing today to get an interpretation of 49 CFR 172.315 marking requirements for 172.315 and am hoping to get some clarification. packages containing limited quantities. I am having trouble determining the intent of I interpret 49CFR 172.315 to read that if a package containing limited quantities is requirements of 172.315 (a) that the shipper does not have to mark the proper shipping the letters UN and the proper Id number in a diamond that meets the the shipper required to put the UN number in a diamond on a package being shipped as a One of my questions arises here. Assuming that the prior statement is correct, is limited quantity. have the diamond, but no where in 49 does it say that if they mark the package with proper I see that they are excepted from marking the shipping name if they the diamond. shipping name and ID number that they are excepted from the marking of the UN number in Basically I pose two questions: quantity shipments that aren't excepted by 3.4.7 of IMDG, required on limited quantity 1. Is the marking that IMDG 3.4.5.1.2 (UN **** in a diamond) requires for limited shipments prepared under 49CFR. do they not have to mark the UN**** in a diamond. 2. If the shipper using 49CFR marks a package with the UN **** and proper shipping name Container Inspection Training and Assistance Team, Your help in this matter is appreciated. I work for the United States Coast Guard as well as for enforcement applications. I have already talked to your help desk about and need clarification for our students this issue, but would like a letter of interpretation to refer students and colleagues. Thanks in advance for your help#

Page 4United States Coast Guard MST3 Steven Webb Container Inspection Training and Assistance#