Hyundai America Shipping Agency — 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 JAN 1 8 2008 Mr. Herb Giles Manager, Hazardous Materials Hyundai America Shipping Agency 7701 Las Colinas Ridge, Suite 400 Irving, TX 75063 Ref No.: 08-0004 Dear Mr. Giles: This is in response to your letter dated November 17,2007 regarding the shipping paper and marking requirements contained in the Hazardous Materials Regulations (HMR; 49 CFR Parts 17 1-1 80) that are applicable to a portable tank containing the residue of a hazardous material. Specifically, you ask for confirmation that the allowance in $ 172.203(e)(l) to include the words "RESIDUE: Last Contained" as part of the description on the shipping paper does not require the proper shipping name marking, provided by § 172.326(a), to be supplemented with the words "RESIDUE: Last Contained." Your understanding is correct. You are not required to supplement the proper shipping name marking on a portable tank containing residue of a hazardous material with the words "RESIDUE: Last Contained." The requirement provided in $ 172.203(e)(l) allows you to include the words "RESIDUE: Last Contained" on the shipping paper in association with the basic description of the hazardous material previously contained in the package. I hope this information is helpful. If you have fiu-ther questions, please do not hesitate to contact this office. Sincerely, Chief, Standards Development ' Office of Hazardous Materials Standards#

Page 217 November 2007 Office of Hazardous Materials Standards Pipeline and Hazardous Materials Safety Attn: DHM-10, US Department of Transportation 400 7th Street SW Washington, DC 20590-0001 Hyundai America Shipping Agency 7701 Las Colinas Ridge, Suite '400 Irving, Texas 75063 re: 172.203(e)(l)and(2) - Shipping Paper Requirements 172.326(a) - Marking of Portable Tank Requirements Encl: (1) Picture of Portable Tank 1. Part 172.203(e) (1) addresses the requirement to supplement the shipping description on a shipping paper to include the words or phrase "Residue Last Contained" before the basic description. Part 172.336(a) addresses the requirement for a portable tank to be marked with the proper shipping name on two opposing sides. 2. Hyundai America requests clarification concerning the marking of portable tanks. Please confirm that the Proper Shipping Name marking on a portable tank does not need to supplemented with the words "RESIDUE: LAST CONTAINED". Specifically, a portable tank being transported had previously been filled with UN3394 ORGANOMETALLIC SUBSTANCE, LIQUID, PYROPHORIC, WATER-REACTIVE (TRIETHYLAMUMINUM), CLASS 4.2(4.3) PG I and only contained residue of that product. The tank was marked on two opposing sides with the PSN - ORGANOMETALLIC SUBSTANCE, LIQUID, PYROPHORIC, WATER-REACTIVE and included the chemical description (TRIETHYLALUMINUM). Enclosure (1) is a picture of the tank markings. 3. Supplementing Proper Shipping Names with the words or phase "Residue: Last Contained" is only a shipping papers requirement and has no impact on the marking of portable tanks. 4. Please confirm if my interpretations above are correct. Best Regards, kerb ~iles Manager, Hazardous Materials Hyundai America Shipping Agency 972-550-2645 a HYUNDAI AMERICA SHIPPING AGENCY, INC. 7701 U S COLINAS RIDGE, SUITE 400, IRVING, TX 75063 TEL: (972) 373-3 100 FAX: (972) 373-31 39#

Page 33394 * CHEMICAL EXTINGUISHER MADE IN USA TEA. EAT P0-4147003432 TANP -USE DRY-Y CARGO ERE ANOID WATER A (TRIETHYLALUMINUM) PYROPHORIC, WATER-REACTIVE ORGANOMETALLIC SUBSTANCE, LIQUID US Z2774 DANGEROUS"" 12/12/2007#