Pfizer, Inc. — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department APR 11 2006 400 Seventh Street, S.W. Washington, D.C. 20590 Pipeline and Administration Hazardous Materials Safety Ms. Debbie Hape Ref. No. 06-0053 Global Transportation Compliance Specialist PGM Global Logistics Pfizer, Inc. 1855 Shelby Oaks Drive North Memphis, TN 38134 Dear Ms. Hape: This is in response to your e-mail dated March 2, 2006 regarding the applicability of the Hazardous Materials Regulations (HMR; 49 CFR Parts 100-180) to shipping papers. You state that the current Voluntary Interindustry Commerce Standards (VICS) standard bill of lading uses the abbreviation "DOT" instead of "Department of Transportation," in the shipper's certification statement required on shipping papers under § 172.204. You ask whether use of this abbreviation is acceptable under the HMR. You also state that the "Weight" column of the current VICS standard bill of lading does not contain the term "Ibs." You ask if this omission is acceptable under the HMR. The certification statement specified in § 172.204(a)(1) must be written as specified and may not be modified. Therefore, use of the abbreviation "DOT" in lieu of "Department of Transportation" in the shipper's certification statement is unacceptable. Section 172.202(a)(5) requires the total quantity of hazardous materials covered by the shipping description to be indicated (by mass or volume, or by activity for Class 7 materials) and must include an indication of the applicable unit of measurement. There is no requirement in the HMR that restricts units of measurement to "lbs." Therefore, the term "Ibs" is not required as a pre-populated field on shipping papers. However, you must provide an indication of a unit of measurement as part of the shipping description. Please do not hesitate to contact us for other inquiries concerning the Hazardous Materials Regulations. Sincerely, Office of Hazardous Materials Standards 060053 172.204#

Page 2VICS Bill of Lading Compliance Page 1 of 2 Drakeford, Carolyn <PHMSA> From: Gorsky, Susan <PHMSA> Sent: Thursday, March 02, 2006 2:58 PM Foster To: Drakeford, Carolyn <PHMSA> 5172.204 6) Subject: FW: VICS Bill of Lading Compliance Shipping Papers Please enter this in the interp data base. Thanks. Susan 86-0053 Sent: Wednesday, March 01, 2006 12:53 PM From: Hape, Debbie [mailto:Debbie.Hape@pfizer.com] To: Gorsky, Susan <PHMSA> Subject: VICS Bill of Lading Compliance Susan, Industry is mandating that the VICS Bill of Lading be used for all shipments. I have two DOT compliance questions relating to the current VICS Standard BOL and hope that you will provide me with an official interpretation. • Although the BOL has been revised in the past two years to now include the DOT-required Shipper compliant with DOT regulations? Per the 49 CFR, the statement must appear as stated in 172.204(a)(1) or Certification, the statement abbreviates the phrase Department of Transportation to "DOT." Is this (a)(2) - neither of these statements contain abbreviations. • In the Carrier Information section, the "Weight" column does not contain the term "Ibs." Is this acceptable per the DOT? We want to be sure that the VICS shipping document is DOT compliant for our hazardous materials shipments. I have attached a copy of the current VICS bill so you can review it in light of my questions. <VICS_BOL.pdf>> Thank you, Susan, I very much appreciate your assistance in this matter. Debbie F. Hape, CHMM Global Transportation Compliance Specialist PGM Global Logistics Pfizer Inc 1855 Shelby Oaks Drive North Memphis, TN 38134 3/3/2006#

Page 3II. The Standard Bill of Lading Form YES Sunder BOL: WWW. VICS ORG Por Complet VES BOL Cudin Information. BILL OF LADING Page Name: SHIP FROM Bill of Lading Number: Address: City/State/Zip: SID#: BAR CODE SPACE SHIP TO FOB: L Name: Location #: _ CARRIER NAME: Trailer number: Address: Seal number(s): City/State/Zip: SCAC: CID#: FOB: D Pro number: Name: THIRD PARTY FREIGHT CHARGES BILL TO: Address: BAR CODE SPACE City/State/Zip: Freight Charge Terms: (freight charges are prepaid SPECIAL INSTRUCTIONS: Prepaid unless marked otherwise) Collect 3rd Party_ (check box) underlying Bills of Lading Master Bill of Lading: with attached CUSTOMER ORDER NUMBER # PKGS CUSTOMER ORDER INFORMATION WEIGHT PALLET/SLIP (CIRCLE ONE) ADDITIONAL SHIPPER INFO N N N N N GRAND TOTAL HANDLING PACKAGE CARRIER INFORMATION QTY UNIT COMMODITY DESCRIPTION L.TL ONLY T TYPE QTY T TYPE WEIGHT H.M. (X) nust be so marked and packaged as to ensure safe transportation with ordinary car commodities requiring special or additional care or attention in handting or stowin Sen Section Z(e) of NMFC Item 360 NMFC # CLASS RECEIVINO STAMP SPACE 8568888 8888888888 1588858877 GRAND TOTAL Where the rate is dependent on value, shippers are required to state specifically in writing the agreed or declared value of the property as follows: COD Amount: $ *The agreed or declared value cf the property is specifically stated by the shipper to be not exceeding per Fee Terms: Collect: • Prepaid: C Customer check acceptable: O RECEIVED, subjact to individua ly determined rates or contracts that have been agreed upon in writing between NOTE Liability Limitation for loss or damage in this shipment may be applicable. See 49 U.S.C. • 14706(c)(1(A) and (B). the carrier and shipper, if applicable, otherwise to the rates, classifications and rules that have been established by the carrier and are available to the shipper, on request, and to all applicable state and federal regulations right and at ather at chargey of this shipment without payment o Signature Shipper SHIPPER SIGNATURE / DATE described. packaged. This is to certify that the above named malerials are property classified, transportation accorting to the applicalsis regulations of the U.S. DOT marked and labeled, and are in proper condition for Trailer Loaded: • By Shipper Ereight Counted: • By Shipper CARRIER SIGNATURE / PICKUP DATE Camer acknowledges receipt of packages and requined placards. Cartier • By Driver • By Driver/pallets said to documantation in the vehicle. certifles emergency response information was made available and/or arner has the U.S. DOT emergency response guidebook or equivaien contain • By Driver/Pieces noted. Property described above is received in good order, excapt as 6#

Page 4I. The Standard Bill of Lading Form VICS Standard BOL: WWW. VICS.ORG For Complete VICS BOL Guideline Information Date: SUPPLEMENT TO THE BILL OF LADING Page Bill of Lading Number: CUSTOMER ORDER INFORMATION CUSTOMER ORDER # PKGS WEIGHT PALLET/SLIP NUMBER (CIRCLE ONE) ADDITIONAL SHIPPER INFO N N° Y N N N N. N N N N Y N N N N PAGE SUBTOTAL HANDLING QTY UNIT PACKAGE CARRIER INFORMATION COMMODITY DESCRIPTION LTL ONLY TYPE QTY TYPE WEIGHT H.M. Commodities routino concial or additional care or aMention in handling or sionin. (x) must be so marked and packaged as to ensure safe transportation with ordinary care See Section 2(e) of NMFC Item 360 NMFC # CLASS PAGE SUBTOTAL#