Hawkins, Inc. — Hazardous Materials Safety Interpretation

Page 1U.S. Department 1200 New Jersey Ave. S 6 of Transportation Nashington DC 20591 Pipeline and Hazardous SEP 6 2007 Administration Materials Safety Mr. Chris W. Gibson EHS&R Manager Ref. No. 07-0151 3100 East Hennepin Avenue Hawkins, Inc. Minneapolis, MN 55413 This is in response to your February 8, 2007 letter concerning the applicability of the Hazardous Materials Regulations (HMR: 49 CFR 171-180) to the location of placards on Intermediate Bulk Containers (IBCs). We apologize for the delay. that these large-radius corners provide an area on which to affix a placard. You also provide In your letter, you state that many IBCs are now built with large-radius corners. You state photographs of a placard affixed on a large-radius corner of an IBC. You ask whether these corners are an acceptable "side" to affix a placard as required by the HMR. an IBC, a large-radius corner is an acceptable area to affix a placard it is the opinion of this Office that provided the placards are affixed on two opposite sides of I hope this information is helpful. Sincerely, Chief, Standards Development Office of Hazardous Materials Standards 1725146) 070151#

Page 2foster HAWKINS, INC. $172.5146) Placarding 07-0151 February 8, 2007 Mr. Edward T. Mazzullo U.S. DOT/PHMSA (PHH-10) Director, Office of Hazardous Materials Standards 400 7th Street S.W Washington, D.C. 20590-0001 RE: Location of Placards for IBC Containers 49 CFR 172.514(c) Dear Mr. Mazzullo: constitutes a "side". Many of the containers are now built with large-radius corners, Due to the variety of construction of IBC containers, the question has arisen as to what presenting an area for which a placard fits. (see Picture 1). This location has the desirable effect that the placard is protected from damage during transportation operations. Picture 1 Picture 2 regulation? Question: Is this location acceptable to the DOT, and in compliance with the above#