Alcoa KAMA — Hazardous Materials Safety Interpretation

Page 1Transportatic .S. Departmer 1200 New Jersey Avenue, SE SEP 5 2007 Washington, D.C. 20590 Alcoa KAMA Mr. Chris Meeks Ref. No. 07-0067R 1050 Sycamore Rd. Manteno, II 60950 Mr. Meeks: This is in further response to our July 28, 2007 reply to your March 30, 2007 letter concerning limited quantity shipments of compressed gases transported by highway. A further review of this issue indicates a need to clarify our previous response. Your letter stated that § 173.306 of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) provides labeling and packaging exceptions for compressed gases only when offered as a limited quantity not exceeding a gross weight of 30 kg (66 pounds). Your letter also stated that a 55-gallon steel drum (1A2) used as an outer packaging to contain aerosols and having a applicable labeling and packaging requirements are maintained. You asked whether your gross weight over 30 kg (66 pounds) may be offered and transported by highway, provided all interpretations were correct. In our response, we indicated that when transported by highway, § 173.306 excepts limited transportation by air); and (2) specification packaging requirements when packaged in quantities of certain compressed gases from: (1) labeling (except when intended for further accordance with paragraphs (a)(1) through (a)(4) of § 173.306, unless required as a condition of the exception. Each package may not exceed 30 kg (66 pounds) gross weight. In addition, these shipments are not subject to: subpart F (Placarding) of part 172; part 174, except § 174.24; and part 177, except § 177.817. It was not out intention to imply that a 55-gallon steel drum is an acceptable packaging for "Exceptions" column of the HMT. The HMR does not authorize aerosols to be transported in a aerosols. The only packaging section for this material is § 173.306 as indicated under the package with a gross weight that is greater then 30 kg (66 pounds). I hope this information is helpful. Sincerely, Chief. Standards Development Office of Hazardous Materials Standards 173.306 (a) 070067R#

Page 2Foster 8173.306 (9) - Alcoa ALCOA Cylinders 1050 Sycar 07-0067 Tel: 1 815 4€ Manteno. IL Fax: 1 815 46 March 23, 2007 Mr. Edward T. Mazzullo Director, Office of Hazardous Materials Standards U.S. DOT/PHMSA (PHH-10) 400 7th Street S.W Washington, D.C. 20590-0001 RE: Request for clarification of 49 CFR 173.306(a) Dear Mr. Mazzullo: I am requesting clarification of section 49 CFR 173.306(a) concerning shipments over the highway of limited quantities of compressed gases. Please verify the following information so that my understanding of this section is correct. • Section 49 CFR 173.306(a) provides labeling and packing exceptions to part 172 or compressed gases only when offered as a limited quantity not exceeding gross weight of 30 kg (66 pounds) • A fifty-five gallon steel drum (specification 1A2) used as an outer packing for ontaining aerosols and having a gross weight in excess of 30 kg (66 pounds) ma e offered and shipped over the highway provided that all applicable labeling an packing requirements of part 172 are obeyed. Please advise. My mailing address can be found in header of this letter. Sincerely, Chris Meeks EHS Manager Alcoa Kama#