Akzo Nobel Chemicals, Inc. — 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 Mr. Mark Connolly Manager, Transportation Regulations and Security Akzo Nobel Chemicals, Inc. 525 W. Van Buren Street Chicago, IL 60706 Ref. No.: 07-02 1 1 Dear Mr. Connolly: This responds to your October 29,2007, letter regarding the description of hazardous materials on shipping papers required under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171 -1 80). Specifically, you request clarification on the following abbreviations used to describe the type of package on a shipping paper: (1) "T/T" or "TT" to describe a cargo tank or a tank truck, and (2) "ISOTANK" to describe an intermodal portable tank? Section 172.202(a)(7) requires the number and type of packages to be indicated on a shipping paper. The type of packages must be indicated by description of the package (e.g., "drum") or abbreviation (e.g. "cyl" for "cylinder"). The abbreviations you provide are commonly accepted and recognizable and thus, may be used to indicate packaging type. I hope this answers your inquiry. Sincerely, / Chief, Standards Development Office of Hazardous Materials Standards#

Page 2AKHB NOBEL October 29, 2007 Mr. John Gale Office of Hazardous Materials Standards (PHH-10) Office of Hazardous Materials Safety Pipeline and Hazardous Materials Safety Administration U.S. Department of Transportation East Building, 2nd Floor 1200 New Jersey Avenue, SE Washington, DC 20590-0001 Subject: for HM-215 E Use of Commonly Acceptable Recognizable Abbreviations Certain Bulk Packages in Accordance with 49CFR172.202 (a) (7) Dear Mr. Gale: Akzo Nobel Chemicals strives to meet the requirements for description of the type of package on the shipping paper. We have received questions about abbreviations for certain package types from carrier personnel confused by their interpretations of Final Rule HM-215E. For Bulk packages we request the clarification for the use of the following abbreviations: "T/T" or "TT" for Cargo Tank "ISOTANK" for the large (approximately 10,500 liters thru 25,000 liters capacity) intermodal portable tank designed to be removed from a chassis for intermodal transport. We have discussed the use of T/T or TT with our tank truck carriers and they are in agreement that this is a common recognizable abbreviation for the package type tank truck. We have discussed the use of the term ISOTANK with personnel from our highway carriers, our lsotank leasing companies, and also ocean carrier personnel. They are in agreement that this is a common recognizable abbreviation for the package type portable tank. Your clarification is appreciated. Regards, Manager, Transportation Regulations and Security Tel# 3 12 544-7 177 Fax# 3 12 544-7087 Email mark.connollv@,akzonobel.com Akzo Nobel Chemicals Inc. 525 W Van Buren Street Chicago IL 60706#