Northern Air Cargo — 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 Smith Hazardous Materials Instructor Northern Air Cargo 3900 Old International Airport Rd. Anchorage, AK 99502 Ref. No. 07-0233 Dear Mr. Smith: This is in response to your December 18,2007 letter regarding the Hazardous Materials Regulations (HMR; 49 CFR 17 1 - 1 80) applicable to marking packages of limited quantities of hazardous materials. Specifically, you ask whether it is permissible to add the proper shipping name to a package containing a limited quantity of hazardous materials and transported domestically by air. As specified by 8 172.301, each person who offers a hazardous material for transportation in a non-bulk packaging must mark the package with the proper shipping and identification number preceded by the letters "LTN" or "NA," as applicable, for the entry as shown in the 8 172.101 Table. As specified in 5 172.3 15, except for transportation by air, a package containing a limited quantity of hazardous materials is not required to be marked with the proper shipping name provided it is marked with the identification (ID) number, preceded by the letters "UN" or "NA," as applicable, for the entry as shown in the 8 172.101 Table, and placed within a square-on-point border. However, for transportation by air, a package containing a limited quantity of hazardous materials is required to be marked with the proper shipping name. Therefore, it is not only permissible, it is required to add the proper shipping name to a package containing a limited quantity of hazardous materials and transported domestically by air. I hope this satisfies your inquiry. If we can be of further assistance, please contact us. Chief, Standards Development Office of Hazardous Materials Standards#

Page 218 Dec 07 NORTHERN AIR CARGO Office of Hazardous Materials Standards Pipeline and Hazardous Materials Safety Administration Attn: PHH-10 U.S. Department of Transportation East Building 1200 New Jersey Avenue, SE. Washington DC 20590-0001. Re: Limited quantity markings for air transport Is it permissible to use the ICAO Technical Instructions method of marking a package of limited quantities with the requirement of adding the proper shipping name to this marking? There is no restriction of its use referenced in 49CFR 17 1.22, 17 1.23 and 17 1.24. There is a question arising from this because in 49CFR 172.3 15 there is an 'and' inserted in the paragraph to make it include the square-on-point border that does not appear or is referenced in the Federal Register HM-2 151. Is this rendition of a limited quantity marking permissible for a domestic air transport shipment under 49 CFR? Paint Related Material In the 2007-2008 ICAO Technical Instructions, 5;2.4.1 states: + "For packages containing limited quantities of dangerous goods, the UN number (preceded by the letters "UN) may be placed within a diamond. If the diamond marking is applied, the following requirements must be met. The width of the line forming the diamond must be at least 2mm; the number must be at least 6mm high. When more than one substance is included in the package and the substances are assigned to different UN numbers, then the diamond must be large enough to include each relevant UN number." NORTHERN AIR CARGO INC 3900 Old International Airport Rd Anchorage AK 99502 907-243-3331 800-727-21 41 FAX 907-249-51 90 WWW.NORTHERNAIRCARGO.COM#

Page 3+ "Note.--- It is anticipated that displaying the UN number within a diamondfor packages containing limited quantities of dangerous goods will become mandatory as of 1 January 2009. " HM-2 151 page FR 78598 dated 29 December 2006 states: "Marking of Limited Quantity shipments. The ICAO Technical Instructions include a marking requirement for packages containing a limited quantity of hazardous material. The mark consists of the identification number of the material placed within a square-on-point border. The marking is anticipated to become effective January 1,2009. Except for transportation by aircraft, this marking is currently authorized under the HMR as an alternative to marking the proper shipping name on the package; we are allowing continued use of this marking to minimize tr-ansportation costs and provide flexibility." 49CFR 172.315 "Except for transportation by aircraft or as otherwise provided in this subchapter, a package containing a limited quantity of hazardous materials is not required to be marked with the proper shipping name provided it is marked with the identification (ID) number, preceded by the letters "UN" or "NA," as applicable, for the entry as shown in the 5 172.10 1 Table, and placed within a square-on-point border in accordance with the following:" Sincerely, Mark Smith Northern Air Cargo Hazardous Materials Instructor 907-249-5 186 NORTHERN AIR CARGO INC 3900 Old International Airport Rd Anchorage AK 99502 907-243-3331 800-727-21 41 FAX 907-249-51 90 W.NORTHERNAIRCARGO.COM#