Alden Leeds, 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 JUN 1 9 2013 Mr. Mark Visconti Alden Leeds, Inc. 55 Jacobus Avenue South Kearny, NJ 07032 Ref No. 13-0113 Dear Mr. Visconti: This responds to your May 15, 2013 request for clarification on how to describe and transport swimming pool chlorinating tablets under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you describe a package configuration and ask if the package complies with the consumer commodity requirements specified in § 173.152(c). In your letter, you indicate that you are shipping swimming pool chlorinating tablets classified as UN2468, Trichloroisocyanuric acid, dry, 5.1, PGII. These tablets are placed in a plastic pail outer package weighing 40 pounds. The tablets are each sealed in clear plastic wrapping as an inner packaging and placed in the outer packaging. Each plastic wrapped inner packaging is 8 ounces. Based on this packaging configuration, you ask the following: Q 1. What is DOT's definition of an inner packaging? A 1. As defined in § 171.8, an inner packaging is a packaging for which an outer packaging is required for transport. It does not include the inner receptacle of a composite packaging. Q2. Do the tablets in the enclosed photos meet the requirement for an inner packaging? A2. Yes, according to your enclosed photos, the tablets, as contained in sealed plastic inner packaging meet the definition of an inner packaging as defined in §171.8. Q3. Does this material and packaging configuration meet the consumer commodity requirement specified in 173 .152( c)? ---· ·--·--·· ---#

Page 2A3. Yes, provided the material meets the definition of consumer commodity specified in § 1 71. 8, each package conforms to the packaging requirements of subpart B of part 173, the overall package does not exceed 30 kg (66 pounds), and, for packing group II solids, the inner packagings do not exceed 1.0 kg (2.2 pounds) net capacity. I hope this answers your inquiry. If you need additional assistance, please call this office at (202) 366-8553. Sincerely, Robert Benedict Chief, Standards Development Branch Standards and Rulemaking Division#

Page 3Manufacturers of ALDEN LEEDS, INC. ,;{fl](t;;fM Swimming Pool Chemicals wu - "Chemicals that care for your pool" 55 Jacobus Ave. • South Kearny, NJ 07032 N[~~'!!!M ldlfHrJtli sSp,at crhkl.e,*l. pec1a y em1ca s May 15,2013 US DOT PHMSA Office of Hazardous Materials Standards Attn: PHH-10 East Building 1200 New Jersey Avenue, SE Washington, DC 20590-0001 Re: Interpretation of Haz Mat Shipping Regulations CFR 173 .152(b )(1 )(c) Alden Leeds has been asked to package an oxidizer which may or may not meet the requirements for a consumer commodity ORM-D package. The product is swimming pool chlorinating tablets, UN2468, trichloroisocyanuric Acid, dry, 5.1, PGIL As per CFR 173.152(b)(l)(c), this package has an outer package (pail) under 66 pounds. In this case it is 40 pounds. The inner packaging has tablets, which are in sealed clear plastic wrapping. Each plastic wrapping of the inner packaging is under the required 2.2 pounds. In this case it is 8 oz. At first glance, it appears that this meets the requirements for consumer commodity ORM-D, but I am not clear what the DOT's definition of an "inner packaging" is .. Do the tablets in the pictures meet the requirement for inner packaging? What is the DOT's definition of inner packaging? Please see enclosed pictures. This package is labeled and shipped in this same matter by many companies now. Alden Leeds wants to be 1 00% certain that this meets the requirements and laws for Consumer Commodity package before we get involved with this project. Please review and mail, email or call with your response. Please reply promptly as I had emailed several times without a response. Rerards, , ~" jf 1r•L l1 ,u 4;~ M~conti Alden Leeds, Inc. mark.visconti@aldenleeds.com 'MU.• cf.t9: The convenient modern way to perfect pool care Out of state- Toll Free- 1-800-TABLETS in NJ- 973-589-3544 FAX- 973-589-5093 E-MAIL ALDENLEEDS@AOL.COM#

Page 4SHIPPING PACKAGE PoolBrand 99% 3# CHLORINATING TABLETS#

Page 5CLOSE UP - LABEL PoolBrand® 99% active 3" CHLORINATING Ingredients TABLETS • Not blended (no fillers) • Kills bacteria and controls algae - • Reduces pH • Leaves no residue • For all types of pools • Individually wrapped tablets Active Ingredient: STEP CHLORINATE Trishloro-s-triazinetrion......99% Other Ingredients: ope Total:.... ... T 2X a week Augitable Chiorine: .: - 100% •..90% KEEP OUT OF REACH OF CHILDREN DANGER See side panels for additional Precautonary Statements and First Aid MADE IN NET WT. 40 LBS THE U.S.A#

Page 6CLOSE UP - ORM.D LABEL STORAGE AND DISPOSAL water, food or feed by storage and disposal. in 37, 000l and well-ventiated area. Avold mom case of spillage, wash with large amounts of water. Aer mie no ping HE M ng matertal. Keep away from fumes, sparks and of an of Rail. tes are acutely hazardous. Improper disposal of ences s o a violation of Federal law. Theoe westes cannot be disposed of ty al one, contaet your State Pesticide or Environmental Gentel Age, er t sentative at the nearest EPA Regional Office for guidance. POSAL: Nonrefitable container. Do not rouse or refil this container. Not Surface throughly with water to diassive all material prior to disposal. Offer Rine He that the Ti 0801376 alien hally ar 1H-the The satire of ticula NAM Water Product Diatributed By: Scutti Charlesten, WV 25303 98 MasCords Avenue SW Webnie www. Poetrant.o Tell Pree: #PY-POOL-URS Pov No. 1019 EPA EPA#

Page 7CLOSEUP LUNTE POCKAGING#