Sandia National Laboratories — Hazardous Materials Safety Interpretation

Page 1Washington, D.C. 20590 400 Seventh Street, S.W. Hazardous Materials Safety Pipeline and Administration APR 16 2007 Mr. Leighton Ford Environmental Management Department Sandia National Laboratories Ref. No.: 07-0060 7011 East Avenue MS 9221 Livermore, CA 94550 Dear Mr. Ford: symbol on packagings (e.g, UN standard or specification drums) in accordance with the This responds to your letter dated March 13, 2007, regarding display of the UN marking or Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Your questions are paraphrased and answered as follows: Q. Section 178.503(a)(1) permits the letters "UN" to be applied in place of the symbol; may be used in the symbol. Is there any distinction between using upper case "UN" however, the regulations do not specifically state that the upper case "UN" letters letters vs. lower case "un" letters in the symbol or in place of the symbol as allowed by § 178.503(a)(1)? A. The answer is yes. The design of the United Nations' symbol is distinctive and allows the United Nations' symbol to be read the same regardless of orientation standard must be marked with the United Nations' symbol (i.e., lower case "un" (upside down or right side up) on the package. A packaging conforming to a UN letters within a circle) as illustrated in paragraph (e) of §178.503. For embossed metal receptacles, the letters "UN" may be used in place of the United Nations symbol on a UN standard or specification package. Q. Section 178.503(a)(1) requires the side marking and the bottom marking to be the same information as that found on the bottom of the drum (permanently embossed) Sub the sed meartie specietion parking of thing ren i remenounderthe HIMR? A. The photographs you provided are unclear. The two black and white photographs of 178.503(a)() 070060#

Page 2UN standard packagings must be marked as specified in §§ 178.3 and 178.503. As prescribed in § 178.3, tor packages with a gross mass of more than 30 kg (66 pounds), the markings must appear on the bottom or the side of the packaging. In accordance with §178.503(a)(1), every new metal drum having a capacity of 100 L must bear the marks described in paragraphs (a)(1) through (a)(6) and (a)(9)(i) in a permanent form on the bottom. The markings on the top, head or side of these packagings need not be permanent. I hope this information is helpful. If we can be of further assistance, please contact us. Sincerely, Edward T. Mazzulle Director, Office of Hazardous Materials Standards#

Page 3Engrum F) sandia National Laboratories § 178.503 (9) Operated are a parat Energy by Leighton Ford Waste Program Engineer Markingof Packagings P.O. Box 96$ ivermore, CA 94551-0969 87-0060 Fax: Phone: (925) 294-4506 Internet: Iford@sandia.gov (925) 294-3418 March 13, 2007 Office of Hazardous Materials Standards (PHH-10) Mr. Edward T. Mazzullo, Director Pipeline and Hazardous Materials Safety Administration U.S. Department of Transportation 400 Seventh Street, S.W., RM 8430 Washington, D.C. 20590-0001 Dear Mr. Mazzullo, have ordered from the manufacturer currently meet DOT specifications. Per your request, Sandia National Sandia National Laboratories/California wants to be sure that the drums and its respective markings that we Laboratories/California is formally asking DOT, in writing, the following questions: in our case, the regulations does not specifically address the notion that the "UN" letters can be used in the. Question 1: It states in 178.503(a) (1) that the letters "UN" may be applied in place of the symbol, however, symbol. Also, is there any distinction between using upper case "UN" versus lower case "un" in the symbol or in place of the symbol as allowed by 178.503(a) (1)? Question 2: Also, 178.503(a) (10) states that the side marking and the bottom marking must be the same information as that found on the bottom of the drum (permanently embossed). Does the side marking and the bottom marking of the drum that we ordered (pictures of marking supplied) comply with this section of marking on the side of the drum with that of the marking on the bottom of the drum to see if meets DOT Sandia National Laboratories/California is enclosing three pictures for your review. Please compare the specifications. Thank you ahead of time for your prompt attention to this matter. I eighton Ford SNL/CA 7011 East Avenue MS9221 Environmental Management Department 925-294-4506 Livermore, CA 94550 (9) Enclosures Exceptional Service in the National Interest#