REGSCAN, Inc. — Hazardous Materials Safety Interpretation

Page 1S. Departme Transportatio Washington, D.C. 20590 400 Seventh Street, S.W. Pipeline and Hazardous Materials Safety Administration NOV 27 2006 REGSCAN, Inc. Mr. Russ Shanahan Ref. No. 06-0256 800 West Fourth Street Williamsport, Pennsylvania 17701 Dear Mr. Shanahan: This is in response to your November 1, 2006 letter requesting clarification under the "Polyester resin kit," UN3269. Specifically, you ask whether the packing group must be Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) concerning the entry included as part of the shipping description. The packing group as designated for a hazardous material in Column 5 of the § 172.101 entries that are not assigned a packing group are excepted from the requirement (see Table must be included in the shipping description for the hazardous material. Generally, § 172.202(a)(4)). In accordance with Special Provision 40 of § 172.102, a polyester resin kit consists of a base material (Class 3, Packing Group II or III) and an activator (organic peroxide). The to the base material, and will be either Packing II or III. The packing group designation packing group for a polyester resin kit is determined using the criteria for Class 3, applied must be included as part of the shipping description on the shipping paper. I hope this information is helpful. If you have further questions, please do not hesitate to contact this office. Sincerely, John A. Cale Office of Hazardous Materials Standards Chief, Standards Development 172.102 172.202(14) 060256#

Page 2REGSCaN. 3172.203 shipping tapers 1256 November 1, 2006 Mr. Edward Mazzullo Director of Hazardous Materials Standards US DOT/OHMS (DHM-10) 400 7th St South-West Washington, DC 20590-0001 RE: Letter of Interpretation Request - UN3269 Packing Groups Dear Mr. Mazzulio, "I am seeking clarification on a particular hazardous material. The Hazardons Material reference Table lists UN3269, Polyester resin kit as having no packing group. However, column (7) • (40) Polyester resin kis consist of two components: a basc inaterial (Ciass 3, Packing Group IT or III) and an activator (organic peroxide), each separately packed in an inner group will be: I on Ill; according to the criteria for Class 3, applied to the base materials special, provision 40, which reads:" I write software to perform hazmat compliance, and I'd like to know the following: Which of the following are legal ways of representing UN3269 on a shipping paper? • Packing Group I • No Packing Group Specification **. • Packing Group I| • Packing Group II Which of the following are illegal ways of representing UN3269 on a shipping paper? • No Packing Group Specification • Packing Group I • Packing Group I Packing Group II Thank you for our time. 4001 pee*s boge Sincerely, perci in: Ruşs Shanahan !:?. Programmer#