Brenntag Mid-South, Inc — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department 1200 New Jersey Ave.. SE Washington, DC 20590 Pipeline and Hazardous Materials Safety Administration OCT 31 2007 Brenntag Mid-South, Inc. Mr. A. B. Eargood Ref. No. 07-0185 1405 Hwy 136 West P. O. Box 20 Henderson, Kentucky 42420 paper for cargo tanks and tanks cars containing the residue of a hazardous material, in This responds to your letter regarding the entry of additional information on a shipping accordance with the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask whether the shipping paper for an empty cargo tank or tank car that contains the residue of a hazardous material must be annotated with the words "Residue Last Contained". the residue of a hazardous material may, but is not required to, include the phrase, The description on the shipping paper for a packaging, such as a cargo tank, containing "RESIDUE: Last Contained * * *" in association with the basic description of the hazardous material previously contained in the packaging (See § 172.203(e)(1)). However, the shipping paper description for a tank car containing the residue of a before the basic description (§ 172.203(e)(2)). hazardous material must include the phrase, "RESIDUE: LAST CONTAINED **** I hope this satisfies your inquiry. If we can be of further assistance, please contact us. Sincerely, / Chic, Sanded Development Office of Hazardous Materials Standards 172.203 (e) 070185#

Page 2BRENNTAG narum 3172.203(e Brenntag Mid-South, Inc. Shipping Papers DIRECTOR OF HAZARDOUS MATERIAL STANDARDS 07-0/85 DEAR SIR, CONCERING TRANSPORTATION OF HAZARDOUS MATERIAL BY RAIL TANK CAR I AM WRITING TO REQUEST A CLARIFICATION TO A QUESTION AND BY HIGHWAY CARGO TANK. 'O HIGHWAY CARGO TANKS AS (e) 2 IS REFERRING TO TANK CARS REGULATION 172.203 (e) 1&2. EMPTY PACKAGING. DOES (e)l refe RESIDUE LAST CONTAINED WHEN PRODUCTS ARE DELIVERED BY HIGHWAY ARE WE REQUIRED TO NOTE ON SHIPPING PAPERS THE WORDS CARGO TANK? HAVE HAD CUSTOMERS TELL THEM THIS REGULATION APPLIES TO TANK CARS DOES THIS REGULATION APPLY ONLY TO TANK CARS. OUR DRIVERS AND HIGHWAY CARGO TANKS. PLEASE LET ME KNOW BY LETTER IF THIS REGULATIONS APPLIES TO CARGO TANKS AUGUST 19,2007 REGULATORY & COMPLIANCE A B EARGOOD BROS HAS 136-505TH, INC. P O BOX 20 HENDEROSN, KY 42420 270-830-1318 beargood@brenntag.com FAX 270-830-1396 Brenntag Mid-South, Inc. PO. Box 20 1405 Highway 136 West Henderson, KY 42419-0020#