DG Supplies, Inc. — Hazardous Materials Safety Interpretation

Page 1Depanmen Washington, D.C. 20590 400 Seventh Street, S.W. lazardous Materials Safet ipeline an Administration JUN 6 2006 Vice President Mr. Michael Bowen Ref. No. 06-0080 DG Supplies, Inc. 239 Prospect Plains Road Monroe Township, NJ 08831 Dear Mr. Bowen: This is in response to your March 22, 2006 letter requesting clarification of the gereral packaging design for liquids, which utilizes molded-pulp inserts to secure glass bortles ranging from 0.5 - 4.0 liters within an outer fiberboard box (with no absorbent). You ask us to assume the completed package satisfies all necessary testing specified in Part 178. You also state the molded-pulp inserts could break down in composition if one of the bottles was to leak its contents. Specifically, you ask if the packaging you described satisfies the general securing and cushioning requirement in § 173.24a(a)(3) for non-bulk packagings and packages. Unless otherwise excepted by the HMR, non-bulk packagings and packages intended to contain section $ 173.24a(a)(3), cushioning material for non-bulk packagings or packages must not have hazardous materials must satisfy the general packaging requirements in § 173.24a. Under its protective properties significantly weakened in the event of leakage. The packaging you describe does not satisfy the requirement because a breakdown in composition of the molded- pulp inserts could significantly weaken the protective properties of the cushioning material. I hope this information is helpful. Please contact us if you require additional assistance. Sincerely,. John Gale Chief, Standards Development Office of Hazardous Materials Standards 173.24a (a)(3) 060080 178.602#

Page 2Eichenlaub 239 Prospect Plains Road $/73.24a Monroe Township, NJ 08831 Phone: 609-860-9220 Fax: 609-860-0096 DG SUPPLIES, INC. 5178.602 E-mail: sales@DGSupplies.com Web: www.DGSupplies.com lesting 06-0080 US Department of Transportation Research and Special Programs Administration Attention: Mr. Ed Mazzullo 400 Seventh Street S. W. Office of Hazardous Materials Standards Washington, DC 20590 March 22, 2006 Dear Mr. Mazzullo, We have been asked by multiple customers to design and test fiberboard package(s) intended to contain liquids and solids for air, ground and ocean shipments. The package would utilize molded-pulp inserts to secure glass bottles ranging from 4 liters down to .5 liters within the outer fiberboard box (with no-absorbent). Assuming the completed package passes all necessary testing outlined in Part 178 could the package still not be authorized for use because of §173.24a (A)(3) in where the molded-pulp inserts could break down in composition if one of the bottles was to leak its contents? I value your time and appreciate your response. Sincerely, MichalBom Michael Bowen Vice President 000000001 3027 ESPECIALISTS IN: Certified Hazardous Material Packaging | Hazardous-Material Spill Control Products | Dangerous Goods Training & Software Certified Infectious and Diagnostic Packaging | Temperature-Controlled Packaging Solutions | Custom Packaging Design & Fabrication Keeping the World Safe... One Shipment at a Time.#