Sun Chemical Corporation — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Avenue, SE Washington, D.C. 20590 NOV 5 2007 Ms. Amy Fishchesser Sun Chemical Corporation 5020 Spring Grove Avenue Cincinnati, OH 45232 Ref. No. 07-01 88 Dear Ms. Fishchesser: This responds to your September 26,2007 letter requesting clarification of the shipping paper requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 17 1-1 80). Specifically, you ask whether the following abbreviations are acceptable for compliance with the requirement to list the type of package(s) on a shipping paper: Package Tvve Abreviation Tote TOTE Dnun DR Pail PL Boxes BOXES Section 172.202(a)(7) requires the number and type of packages to be indicated on a shipping paper. That section permits the use of abbreviations to indicate package type provided the abbreviations are commonly accepted and recognizable. It is the opinion of this office that the package type abbreviations that you provided in your letter are both commonly accepted and recognizable and are acceptable for describing the type of package(s) on a shipping paper. I hope this information is helpful. Please contact us if you require additional assistance. Sincerely, Chief, Standards Development / Ofice of Hazardous Materials Standards#

Page 2Drakeford, Carolyn <PHMSA> From: Sent: To: Subject: 312; o o h 0 t k ~ e ~ INFOCNTR <PHMSA> Thursday, September 27, 2007 2:50 PM ~rakefoid, carolyn <PHMSA> FW: Information Center Comments/Questions Carolyn, Could you process this as a formal request for interpretation? Thanks. Erin ----- Original Message----- From: amy.fischesser@na.sunchem.com [mailto:amy.fischesser@na.sunchem.corn] Sent: Wednesday, September 26, 2007 4:28 PM To: INFOCNTR <PHMSA> Subject: Information Center Cornments/Questions Below is the result of your feedback form. It was submitted by Amy Fischesser (amy.fischesser@na.sunchem.com) on Wednesday, September 26, 2007 at 16:27:45. Name: Amy Fischesser Category: Hazardous Materials Table, Special Provisions, Hazardous Materials Communications Organization: Sun Chemical Corporation Street: 5020 Spring Grove Avenue City: Cincinnati State: Ohio Zip Code: 45232 Phone: 513.484.7657 Fax: 513.632.1531 Comments: RE: 172.202(a)(6)requesting clarification. Sun Chemical ships our hazmat in totes, drums; pails, boxes. When we ship we descibed as follows: (e.9.) 2 TOTE; 3 DR; 2 PL; 2 BOXES. Wilson Trucking has advised Sun Chemical that we have to say 2 IBC; 2 DRUMS. They said that Tote; DR & PL are not acceptable terminology and abbreviations. The gentleman I spoke with at Wilson Trucking (Ron Maxey) said he attended a PHMSA class in May in Raleigh, NC and Jack Witley from PHMSA said that totes had to be referred to as IBCs and that the abbreviation DR was unacceptable and had to be spelled out as "DRUM". I talked with Mike Stevens on the DOT Hotline and he said Sun was not out of compliance -- we are okay with how we are describing our packaging. He said that as long as the trucking company/carrier is clear as to what they are accepting and a DOT inspector would be, we were okay. However, Wilson Trucking will not accept this conversation I had with Mike Stevens. I would appreciate clarification on what is acceptable and what is not acceptable. If Sun I#

Page 3I I must use the term IBC instead of Tote, this will involve a major computer change 0 Thank you very much for your assistance. Amy Fischesser Corporate Hazardous Goods Transportation Manager Sun Chemical Corporation#