Brenntag Mid-South, Inc. — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration WAY, 1 3 28U8 Mr. A.B. Eargood Brenntag Mid-South, Inc. P.O. Box 20 Henderson, KY 42420 1200 New Jersey Avenue, SE Washington, D.C. 20590 Reference No. 08-0 108 Dear Mr. Eargood: This is response to your April 1 1,2008 letter concerning the Hazardous Materials Table ($ 172.101) entry for "UN 1791, Hypochlorite solutions, 8 (corrosive), PG 11" in the October 1,2007 edition of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171 -1 80). You asked if the "PG 111" designation present in earlier editions of the HMR had been inadvertently deleted. The answer is yes. The PG I11 entry for the proper shipping name hypochlorite solutions was inadvertently removed when this entry was revised in a December 29,2006 final rulemaking published under Docket No. PHMSA-06-25476 (HM-2151; 71 FR 78596, 78622). This error will be corrected in a future rulemaking. In the interim, the PG I11 entry may continue to be used for hypochlorite solutions that meet the defining criteria for a PG I11 Class 8 liquid prescribed in $ 173.137. Thank you for bringing this matter to our attention. I hope this information is helpful. Hattie L. Mitchell Chief, Regulatory Review and Reinvention Office of Hazardous Materials Standards#

Page 2BRENN Brenntag Mid-South, Inc. ~ [ T z - /of App I i~b'\l? 08-010 ASSOCIATE ADMINSTRATOR FOR HAZARDOUS MATERIALS SAFETY, RESEARCH AND SPECIAL PROGRAMS ADMINSTRATION DEAR SIR, THERE IS A TYPO IN 49CFR172.101 REGARDING HYPOCHLORITE SOLUTIONS, PG 111. IF YOU LOOK ON-LINE AT THE REVISION DATE 10-01-07, YOU WILL SEE THAT THE PG 111 LISTING HAS BEEN INADVERTENTLY DELETED. MAY I HAVE A LETTER FROM YOUR OFFICE STATING THAT THIS IS CORRECT SO THAT WE ARE QUESTIONED DURING DOT DRIVER STOPS OR A INSPECTION AT ONE OF OUR FACILITIES WE WILL HAVE ON FILE THIS INFORMATION. IF POSSIBLE I NEED A COPY FAXED TO MY ATTENTION AT 270-830-1396. A B EARGOOD A B EARGOOD BRENNTAG MID-SOUTH,INC. P 0 BOX 20 HENDERSON,KY 42420 beargood@brenntag.com Phone 270-830-1318 Fax 270-830-1396 Brenntag Mid-South, Inc. 1405 H~ghway 136 West PO. Box 20 Henderson, KY 42419-0020#