Environmental Management, Inc. — 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 APR 0 2 2011 Jamie Newton Waste Disposal Coordinator Environmental Management, Inc. 5200 N.E. Highway 33 Post Office Box 700 Guthrie, OK 73044-0700 Reference No.: 11-0291 Dear Jamie Newton: This is in response to your November 10, 2011 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You ask several questions pertaining to the identification numbers of hazardous materials. Your questions are answered as follows: Ql. When the HMR refers to the identification number are they referring to just the numerical digits in Column ( 4) of the § 172.101 Hazardous Materials Table? Al. The HMR does not specifically define whether the term "identification number" refers to just the numerical digits in Column (4) of the §172.101 Hazardous Materials Table or also includes the prefix "UN," "NA," or "ID." The identification numbers preceded by the letters "UN" are associated with proper shipping names appropriate for both domestic and international transportation. Those preceded by the letters "NA" are only used in domestic transportation and are not recognized internationally, except to and from Canada (see § 172.101(e)). Under Docket HM-215K (76FR 3308;1/19/11), paragraph (e) of § 172.101 added an explanation for identification numbers associated with certain descriptions under the International Civil Aviation Organization's Technical Instructions for the Safe Transport of Dangerous Goods by Air (ICAO Technical Instructions) and are preceded by the letters "ID." 02. Are the letters "UN" or "NA" optional on the markings required by § 172.332? A2. The use of the letters "UN" or "NA" is not optional as part of the identification number. Identification number markings must be displayed on bulk packagings in accordance with § 172.332. Section 172.332 provides three options for displaying an identification number marking. Identification numbers (numerals only) may be displayed on: (1) an orange panel; (2) a placard; or (3) a plain white square-on-point display configuration as prescribed in § 172.336(b ). The International Maritime Organization's Dangerous Goods Code (IMDG Code) and the United Nations Recommendations on the Transport of Dangerous Goods:#

Page 2Model Regulations (UN Model Regulations) also specify the display of identification number markings on bulk packagings without the "UN" prefix. Q3. Are the letters "UN," "NA," or "ID" optional in the proper shipping description of a hazardous material? A3. The use of the letters "UN," "NA," or "ID" is required to be included as part of the identification number in the shipping description of a hazardous material on a shipping paper. The shipping description must include the identification number (with the letters "UN," "NA," or "ID"), the proper shipping name, hazard class, and packing group, for example: "UNl 090, Acetone, 3, PGII." The ICAO Technical Instructions, IMDG Code, and the UN Model Regulations also require the use of the prefix "UN" or "ID" with the identification number in the shipping description. I hope this satisfies your inquiry. Please contact us if we can be of further assistance. Y2'tir4o· Delmer Billings Senior Regulatory Advisor Standards and Rulemaking Division#

Page 3.. , .. ,. •' ' "· ,- _!.;' •. • ; \. ..... ' Environmental MANAGEMENT November 10, 2011 U.S. DOT PHMSA Office of Hazardous Materials Standards Attn: PHH-1 0 East Building 1200 New Jersey Avenue, SE. Washington, DC 20590-0001 f. To Whom It May Concern: Re: 172.101(e), 172.202(1) and 172.332 Please accept this letter as a request for a formal interpretation from your office. \,.. Environmental Management, Inc. wishes to receive clarification of what, exactly, constitutes the l · "Identification Number" of a hazardous material. Question 1: When the HMR refers to the identification number, are they referring to just the numerical digits in column 4 of the Haz Mat Table? Question 2: Are the letters UN or NA Optional on the markings required by 172.332? Question 3: Are the letters UN or NA optional in the proper shipping description of a hazardous material? ·· · Example: 1993, Flammable Liquid, N.O.S., (Acetone, Toluene) 3, PGIII Thank you in advance for your time and input on these questions. Please contact me at .jnewton@emiok.com, or ( 405) 282-8510 if there is a need for clarification to adequately address these questions. ie Newton Waste Disposal Coordinator Environmental Management, Inc. for an environment we c::u1 an Hve witlht today .& tomonow Post Office Box 700 I Guthrie, Oklahoma 73044-0700 I 405 282-8510 I Web Site: WWWEMIOK.com#