PCS Sales (USA), Inc — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation 1200 New Jersey Avenue, SE Washington, D.C. 20590 Materials Safety Pipeline and Hazardous Administration JUL 2 4 2014 Mr. Tracey G. Smith Manager, Regulatory Compliance PCS Sales (USA), Inc. 110 Skokie Boulevard, Suite 400 Northbrook, IL 60062 Ref No.: 14-0107 Dear Mr. Smith: This responds to your May 27, 2014 email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) with regard to the basic shipping description on shipping papers when there is no packing group shown in the §172.101 Hazardous Materials Table (HMT). Specifically you ask, if there is a packing group assigned to UN2426, Ammonium nitrate, liquid, and if there is not, how the basic description on the shipping paper should read. There is no packing group associated with UN2426, Ammonium nitrate, liquid. The only authorized packaging in the HMR for Ammonium nitrate, liquid, is set forth in §173.243, which prescribes bulk packaging for certain high hazard liquids and dual hazard materials that pose a moderate hazard. Section 172.202(a)(4) requires that the packing group in Roman numerals, as designated for the hazardous material in Column (5) of the §172.101 HMT, must be entered on the shipping paper, but states that entries that are not assigned a packing group are excepted from this requirement. Therefore, the basic shipping description for Ammonium nitrate, liquid would be "UN2426, Ammonium nitrate, liquid, 5.1." I hope this information is helpful. If you have any more questions, please do not hesitate to contact this office. Sincerely, That Olit Robert Benedict Chief, Standards Development Standards and Rulemaking Division#

Page 2O'Donnell 3172.101 • Drakeford, Carolyn (PHMSA) Applicability Sent: From: INFOCNTR (PHMSA) Ward, cray ,4327 PM 14-0107 To: Subject: FW: Packing Group Assignment for UN2426 - Formal Interpretation Requested Hi Carolyn, This caller requested we submit this e-mail as a formal letter of interpretation. Thanks, Victoria From: IGSmith@potashcorp.com [mailto:TGSmith@potashcorp.com] Sent: Tuesday, May 27, 2014 12:51 PM To: PHMSA HM InfoCenter Subject: Packing Group Assignment for UN2426 - Formal Interpretation Requested I have been asked by a number of my customers why UN2426 "Ammonium Nitrate, Liquid" (hot concentrated solution) is or if it is blank in the column 5 we just leave it blank on a shipping description? not assigned a packing group since it is classified in the HMT as a 5.1 oxidizer. Is there a packing group for this commodity Mr. Tracey G. Smith Manager, Regulatory Compliance PCS Sales (USA), Inc. Phone#: 847-849-4358 Mobile#: 847-208-2727 Office Hours are 7:30am - 4:00pm Central Time Fax: 847-849-4692 Email: tgsmith@potashcorp.com nmediately, and delete the original and any copies. Any use of this message without approval by PCS is prohibite his message may contain confidential Information. If you are not the designated recipient. please notify the sende 1#