Johes-Blair Company — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Avenue SE Washmgton. DC 20590 Mr. Matt Barfknecht Jones-Blair Company 2728 Empire Central Dallas, TX 75235 Reference No. 11-0099 Dear Mr. Barfknecht: This responds to your April 27, 2011 email regarding the limited quantity marking requirements of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) as amended under final rule HM-215K (76 FR 3308; January 19,2011). Specifically, you request confirmation that the tan color of the boxes used by your company to package limited quantity hazardous material provides a suitable contrasting background for the limited quantity marking as illustrated in a picture you provided to us. Based on the picture provided, the color of the packaging provides a suitable contrasting background for the limited quantity marking. As amended under HM-215K, § 172.315( a )(2) requires the top and bottom portions and the border forming the square-onpoint (Le., the limited quantity marking) to be black and the center white or of a suitable contrasting background. To rephrase, the center of the limited quantity marking must be white or of a suitable contrasting color to the black top and bottom portions and the border. Printing the limited quantity marking on a fiberboard box in the manner illustrated by the picture you provided meets this condition. I trust this satisfies your inquiry. Please contact us if we can be of further assistance. Sincerely, Ben Supko Chief, Standards Development Branch Standards and Rulemaking Division#

Page 2Drakeford, Carolyn (PHMSA) From: Betts, Charles (PHMSA) Sent: Wednesday, April 27, 2011 12:31 PM To: Drakeford, Carolyn (PHMSA) Subject: FW: Question regarding new Limited Quantity Mark Attachments: LQ tan,JPG; LQ White,JPG Please log this in for expedited handling From: Matt Barfknecht [mailto:mattb@jones-blair.com] Sent: Wednesday, April 27, 2011 8:57 AM To: Betts, Charles (PHMSA) Subject: Question regarding new Limited Quantity Mark Mr. Betts, We are in the process of changing to the new limited quantity mark as required by 172.315. I have attached two pictures for your review. I would like to print the black diamond on our tan boxes and avoid printing white. My questions is does the black over tan provide a "suitable contrasting background"? Thank you for your time. Matt Barfknecht Plant Manager .Jones-Blair Company 21.4-353-1.600 1#