Woodard and Curran, Inc. — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration I!;?,? 2 3 2000 1200 New Jersey Avenue, SE Washington, D.C. 20590 Mr. Kelly V. Camp Woodard and Curran, Inc. 95 Cedar Street, Suite 100 Providence, RI 02903 Ref. No. 08-0092 Dear Mr. Camp: This is in response to your request for clarification of the marking requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 17 1 - 1 80) for packages containing limited quantities. Specifically, you request confirmation of your understanding that technical names are not required to be marked on packages containing limited quantities if they are marked in accordance with 5 172.3 15. As specified in 5 172.3 15, except for transportation by aircraft or if otherwise stated in the HMR, marking the package with the identification number inside a white square on-point configuration identifies the material as a limited quantity and fulfills the general marking requirements in 5 172.301(a)(l). If you use this option to identi@ a package containing a limited quantity, you are not required to mark the shipping name or technical name on the package. If you choose to mark the package with the shipping name, then a technical name may be added, but, provided the requirements of 5 172.3 15 are met, the technical name is not required. I hope this information is helpful. Please contact this office should you have additional questions. Hattie L. Mitchell Chief, Regulatory Review and Reinvention Oflice of Hazardous Materials Standards#

Page 2COMMITMENT & INTEGRITY 95 Cedar Street ( Suite 100 T 800.985.7897 DRIVE RESllLTS Providence, Rhode Island 02903 T 401.273.1 007 www.woodardcurran.com F 401.273.5087 March 25,2008 Q @ Office of Hazardous Materials Standards Pipeline and Hazardous Materials Safety Administration WOODARD Attn: PHH-10 &CURRAN U.S. Department of Transportation East Building 1200 New Jersey Avenue, SE. Washington, DC 20590-0001. RE: Questions About Marking, 49 C.F.R. 172.315 49 C.F.R. 172.315 states that limited quantities do not have to be marked with the proper shipping name if marked in accordance with this section. Since technical names are marked in association with the proper shipping name, please confirm that technical names are not required when limited quantities are marked in accordance with 49 C.F.R. 172.315. Thank you for your help in addressing these questions. I can be reached at 401.273.1007 ext 2009 if you need clarification. Sincerely, WOODARD & CURRAN INC.#