Hazardous Material Distribution Consultant — Hazardous Materials Safety Interpretation

Page 1.s. Departmen f Transportatiol SEP - 8 2006 Washington, D.C. 20590 400 Seventh Street, S.W Pipeline and Hazardous Materials Safety Administration Mr. Randolph Martin Reference No.: 06-0175 Hazardous Material Distribution Consultant 1007 Market Street, Room D-5100 DuPont Global Logistics Wilmington, DE 19898 Dear Mr. Martin: This responds to your letter concerning Special provision B69 assigned to the proper shipping name "Sodium cyanide, solid, UN 1689" in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Your questions are paraphrased and answered as follows: Q1. Special provision B69 reads: "Dry sodium cyanide or potassium cyanide may be shipped in specification bins. Bins must be approved by the Associate Administrator." Does the phrase sift-proof weather-resistant covered hopper cars, covered motor vehicles, portable tanks or non- "sift-proof weather-resistant" apply to all of the bulk packagings identified in the special provision? proof and weather resistant. Al. The answer is yes; all bulk packagings authorized by Special provision B69 rust be sift Q2. Are bins the only bulk packaging that requires approval by the Associate Adrinistrator? A2. The answer is yes; out of the packagings authorized in B69, only bulk bins require approval by the Associate Administrator. Q3. Does Special provision B69 authorize use of non-specification portable tanks without obtaining an approval from the Associate Administrator? A3. The answer is yes; approval is not required for non-specification portable tanks authorized by Special provision B69. I trust this satisfies your request. Sincerely, Hattie L. Mitchell Office of Hazardous Materials Standards Chief, Regulatory Review and Reinvention 172./02 (c)3). 060175 Special Provision B69#

Page 21007 Market Street DaPont Sourcing & Logistics Wilmington, DE 19*98 OU POND DuPont Global Logistics Corbin 3|12. 102 (E) (s) August 1, 2006 Special Provision B 69 Packagings Director, Office of Hazardous Materials Standards Mr. Edward T. Mazzullo 06-0175 400 7th Street S.W U.S. DOT/PHMSA (PHH-10) Washington. D.C. 20590-0001 Dear Mr. Mazzullo: Sodium Cyanide. The Special Provision currently reads: We have a few questions on the interpretation of 49CFR, 172.102(c)(3). Special Provision B69, as it relates to the shipment of dry vehicles, portable tanks or non-specification bins. Bins must be approved by the Associate Administrator. Dry sodium cyanide or potassium cyanide may be shipped in sift-proof weather-resistant metal covered hopper cars, covered motor Another question relates directly to the meaning of "portable tanks". it seems that this SP allows shipment in a number of non- Does "sift-proof weather-resistant" only refer to the "metal covered hopper cars" or does it apply to the other listed packagings as well? the correct interpretation? And finally, does this SP allow the use of non-specification portable tanks without any additional approval? specification packagings, and that only one, the bins, require any additional approval. Is this the correct interpretation? If not. what is Your prompt attention is greatly appreciated. Sincerely. Ruati Randolph Martin Hazardous Materials Distribution Consultant 1007 Market Street. Room D-5100 DuPont Global Logistics Wilmington, DE 19898 FAX: (302) 355-2889 Phone: (302) 773-4248#