5N Plus Wisconsin, Inc. — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department 1200 New Jersey Avenue, SE Washington, D.C. 20590 Materials Safety Pipeline and Hazardous Administration OCT 2 4 2014 Ms. Laura Buholca Plant Manager SN Plus Wisconsin, Inc. 6474 Blanchar's Crossing Windsor, WI 53598 Ref. No. 14-0136 Dear Ms. Buholca: This responds to your July 11, 2014 request for clarification on the reuse of metal and plastic drums under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if you need a wall thickness marking on the UN 1H2 drum (used as the outer packaging of a combination packaging) used to transport "UN3260, Corrosive solids, acidic, inorganic, n.o.s. (gallium trichloride), 8, PGII," under the reuse provisions in § 173.28(b)(4). In a conversation with a member of our staff in the Hazardous Materials Information Center (HMIC), you asked if the wall thickness marking is required to reuse a UN 1H2 plastic drum. The HMIC informed you that under § 173.28(b)(4) the wall thickness marking is required to be marked on the drum if it is the outer drum of a composite packaging or a single packaging. It is your understanding then that combination packaging is not required to be marked with the wall thickness under the reuse provisions in § 173.28(b)(4). Your understanding is correct. In accordance with §§ 173.28(b)(4) and 178.503(a)(9), plastic drums used as single packagings or outer packaging of composite packagings and intended to e reused must be marked with the minimum wall thickness of the packaging material. Thus plastic drum of a combination packaging is not required to be marked with the wal thickness. The packaging scenario you illustrate is considered a combination packaging by definition and is not required to be marked with the wall thickness under the reuse provisions in § 173.28(b)(4). I hope this answers your inquiry. If you need additional assistance, please contact this Office at (202) 366-8553. Acting Chief, Standards Development Branch Standards and Rulemaking Division#

Page 2Boothe 178.503 173,29 Goodall, Shante CTR (PHMSA) From: INFOCNTR (PHMSA) Markings f Packings Sent: Monday, July 14, 2014 4:07 PM To: Hazmat Interps 14-0136 Subject: FW: letter of interpretation Hi Alice and Shante, We received this request for a letter of interpretation. Thanks. -Adam From: Laura Buholca [mailto:Laura.Buholca@5nplus.com] Sent: Friday, July 11, 2014 3:10 PM To: PHMSA HM InfoCenter Subject: letter of interpretation Good afternoon, I spoke to Adam earlier today and received a very good interpretation on the topic; however, in order to satisfy my customers request, I would like to receive letter of interpretation, because our goal is to be in complete compliance and transport our haz mat product safely. 5N PLUS 1 Fastening ausche»#

Page 3Material we are shipping: UN3260 Corrosive Solids, Acidic, Inorganic, N.O.S. (Gallium Trichloride) CLASS 8 PG IT Here is the packaging what we are using: - Material (7.5 kgs) is being placed in glass ampule; seal tape is applied; ampule is placed in fibreboard drum with foam ushioning, it is packaged tight filling all space between bottle and fibreboard drum (picture on lower left); fibreboar rum is sealed with tape and placed in plastic bag and bad is sealed; all that is inserted into blue outer drum; foan cushioning fills space between fibreboard drum and blue drum; Blue drum is sealed; The question is regards outer drum; drum is UN certified, but has no wall thickness identified on the drum. Here is the specifications for the drum: IH2 X225/S/12 DABAN 9624 My question is - do we need a wall thickness, any additional certification or anything else possible that I've overlooked regards this outer drum that would limit us from re-using this drum for future shipments. Please do not hesitate to contact me if there is any additional information needed. 2 12f Many thanks Laura Laura Buholca | Plant Manager 5N Plus Wisconsin Inc. 6474 Blanchar's Crossing, Windsor, WI 53598 170 2 T. 608-846-1357x8004 F. 608-846-1394 c. 608-512-9319 Confidentiality: This message is intended solely for the addressee or the entity to which it is addressed and may contain information which is privileged eproduction of this document is strictly forbidder confidential or protected from disclosure. If you are not the intended recipient, please notify us immediately and destroy this document. Any use, copying o 2#