Schlumberger, Ltd. — Hazardous Materials Safety Interpretation

Page 1Washington, D.C. 20590 400 Seventh Street, S.W. pieterias Sately Administration SEP 18 200g Mr. Paul Lezak 14910 Airline Road Schlumberger, Ltd. Ref. No.: 06-0173 Rosharon. TX 77583 Dear Mr. Lezak: This is in response to your August 3, 2006, letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask whether overpacks containing explosive materials need to be marked with appropriate EX-numbers. The HMR do not require the marking of EX-numbers on overpacks. Section 173.25 requires each overpack to be marked with the proper shipping names and identification numbers required under the HMR for each hazardous material contained within the overpack, unless those markings are visible. The other marking requirements in § 173.25 are conditional scenario. Therefore, dual marking of the EX-numbers on both the packages and overpacks is marking requirements that are unrelated to EX-number markings and are irrelevant to this not required. However, to avoid the possible frustration of your shipment you may include on the shipping paper, in association with the shipping description, the EX-number, product code, or national stock number of each explosive item described under a proper shipping I hope this satisfies your request. Sincerely, that OBat Charles E. Betts Senior Transportation Specialis Office of Hazardous Materials Standard 173•25 060173#

Page 2Jarman, Erin <PHMSA> From: To: Sent: lezak@slb.com BAH FOCATA &PHS. 2006 10:53 AM Subject: Information Center Comments/Questions $173.25 $173.320 Below is the result of your feedback form. on Thursday, August 3, 2006 at 10:53:10. It was submitted by Paul Lezak (lezak@slb.com) OVERPACK Email: lezak@slb.com 06-0173 Name: Paul Lezak 'ategory: Shippers-General Requirements for Shipments and Packagings (Sections 173.1 - Organization: Schlumberger Street: 14910 Airline Road City: Rosharon State: Texas Zip Code: 77583 Phone: 281-285-5676 Fax: 281-285-5477 Comments: Dear Mr. Edward I. Mazzullo, I need to know if an overpack containing explosive materials is required to be marked with the EX-Numbers of the explosive packages contained inside the overpack. and proper labels. 173.25 (a) (2) requires the outside of the overpack to be marked with the P'SN's, ID number's list the EX-number, product code, or national stock number. Section 172.320 explains how the outside of a package containing explosive materials must I contacted the DOT toll free number and requested guidance regarding this question. individual intially stated the EX-number should be marked on the outside of an overpack, The and if more than 5 packages containing EX-numbers are contained inside the overpack, at least 5 EX-numbers should be listed on the overpack. I was then placed or. hold while the later the individual communicated that he found some evidence that the EX-number did not individual investigated if he could find a definitive ruling on this topic. A few minutes have opinion was that we should place EX-numbers on the outside of an overpack.. to be on the outside of an overpack, recommended I send your office an email requesting guidance. Please advise. He also Best regards, Paul Lezak#