3M Package Engineering, 3M Sourcing Operations — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Ha2ardous Materials Safety Administration 1200 New Jersey Ave.. S E Washington. DC 20590 JUL 3 1 2008 Mr. William Gramer Specialist, 3M Package Engineering 3M Sourcing Operations 3M Center 2 16-02N-08 St. Paul, MN 55 144- 1000 Ref. No. 08-0089 Dear Mr. Gramer: This responds to your March 26,2008 letter requesting clarification of the second sentence of "Note 2" in Explosive Package Instruction 1 15 in 173.62 of the Hazardous Materials Regulations (HMR, 49 CFR Parts 1 7 1 - 180.) Specifically, you request clarification or confirmation of your understanding of this requirement in the HMR. In Packing Method 1 15, the second sentence states that a composite package consisting of a plastic receptacle in a metal dnun (6HA1) may be used in lieu of combination packaging. This means that a composite UN 6HA1 plastic inner receptacle within an outer metal package may be shipped as a PG I1 certified single package in lieu of a combination package. A Class 1 material appropriately packaged in accordance with Packing Method 1 15, Note 2, in a composite package 6HA1 does not require additional outer packaging or absorbent material specified for other liquid explosives covered and packaged in combination packagings according to Note 1. I hope this answers your inquiry. Sincerely, Susan Gorsky Acting Chief, Standards Development Office of Hazardous Materials Standards#

Page 23M Sourcing Operations 3M Center, Bldg. 216-2N-07 St. Paul, MN 55 144-1000 Mr. Edward T. Mazzullo Director, Office of Hazardous Materials Standards Pipeline and Hazardous Materials Safety Administration U.S. Department of Transportation, East Building 1200 New Jersey Avenue, SE Washington, DC 20590-0001 Attention: Office of Hazardous Iklaterials Standards, PHH-10 (Second Floor, E24-314) Subject: Interpretation Letter Request 26 March 2008 Dear Mr Mazzullo, We are writing to confirm or clarify our understanding of the second sentence of "Note 2" within Explosive Package Instruction 115 in section 49 CFR 9173.62. When a material is covered and packaged according to Note 2 (EX #s that specify UN #s 0075, 0143, 0495, and 0497), the second sentence of the note in this instruction states that "...A composite package may be used in lieu of combination packaging". We believe this to mean that a composite UN 6HA1 plastic inner receptacle within an outer metal package may be shipped as a PG I or II certified single package '...in lieu of a combination package...', and thus without the need for additional outer packaging or absorbent material specified for other liquid explosives covered and packaged in combination packagings according to Note 1. Would you please confirm or clarify our understanding? As this applies to a shipment related to a Department of Defense (DOD) contract, may we please have a reply by April 30th, 2008? Thank you in advance. If you have need of any further information please use any of the means below to contact me, including my direct phone and electronic mail address. f! Vllil!iam Gramer, 6' Specialist, 3M Package Engineering 3M Center 216 - 02N- 08 St Paul, MN 55144 - 1000 USA Direct Phone: 651 736 1407. Electronic Mail: w~ramer@mmm.com#