North America Dangerous Cargo (Maersk) — 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 NOV 2 1 2014 Charles A. Giglia North America Dangerous Cargo (Maersk) 9300 Arrowpoint Blvd. Charlotte, NC 28273-8136 Ref. No. 14-0160 Dear Mr. Giglia: This is in response to your e-mail requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR 171-180) applicable to shipping papers. Specifically, you ask whether your attached dangerous good manifest includes an acceptable format for identifying the container identification number in box 15. Shipping paper requirements are specified in §§ 172.200 through 172.204 of the HMR. Section 172.202(a)(5) requires identifying the number and type of packages on a shipping paper. However, the HMR does not require identifying the container identification number on a hazardous materials shipping paper. The container identification number is additional information. Unless otherwise permitted or required by the HMR, additional information may be placed after the basic description required by § 172.202(a) of the HMR. I trust this satisfies your inquiry. Please contact us if we can be of further assistance. Sincerely, -FAnn Foster T. Glenn Foster Chief, Regulatory Review and Reinvention Standards and Rulemaking Division#

Page 2Lehman §172.203 Dodd, Alice (PHMSA) Shupping 14-016C Papers From: Sent: Ciccarone, Michael CTR (PHMSA) To: Friday, August 22, 2014 3:31 PM Subject: Hazmat Interps Attachments: DGD.doc FW: Multimodal Dangerous Goods Form Shante and Alice, Please submit this for.a formal letter of interpretation. Mr. Giglia spoke to Raleigh Davis in the HMIC. Thanks, Mike From: Charles.A.Giglia@maersk.com [mailto:Charles.A.Giglia@maersk.com] Sent: Friday, August 22, 2014 9:49 AM To: PHMSA HM InfoCenter • Cc: Andrew.Dugan@maersk.com Subject: Multimodal Dangerous Goods Form Office of Hazardous Material Standards U.S.DOT / PHMSA Washington, DC 20590 Hi, Would like to respectfully request an interpretation in regards to the Multimodal Dangerous Goods Form. We have a customer that moves UN3171 Electric Vehicles, 2 per container, same every time. He books shipments of 50+ containers at a time. They are looking to make one Dangerous Goods Declaration, for, let us say 15 containers per document. In box 15 of the MDGF, they would state see attached rider (for example ) and attach a list of loaded containers, again the same cargo, amount and weight in each, and sign and fill in Box 20. Is it acceptable for this document to list multiple containers as stated? Rgds Charles A. Giglia Manager North America Dangerous Cargo Maersk 9300 Arrowpoint Blvd. Charlotte, NC, 28273-8136 Reg No. 13-5159146 Work :704-571-5329#

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Page 41 Shipper/Consignor/Sender MULTI MODAL DANGEROUS GOODS FORM 2 Transport document number 3 Page 1 of 14 Shipper's I reference I reference 5 Freight Forwarder's 6 Consignee by the carrer 7 Carrier (to be completed hereby declare that the contends of this consignment are fully and accurately SHIPPER'S DECLARATION descriced below by the proper shipping name, and are classified, packaced transport according to the applicable international and natlonal govemment marked and labelled/placarded and are in all respects in proper condition for 8 This shipment is within the limitations prescribed for regulations PASSENGER AND 9 Additional handling information CARGO AIRCRAFT CARGO AIRCRAFT 10 Vessellight no. and date 11 Poriptace of loading 12 Port/place of discharge 13 Destination 14 Shipping Marks *Number and kind of packages; description of goods Gross mass (kg) Net mass Cube (ma) registration No. 15 Container identification No./ vehicle 16 Seal numbers) type 17 Contalner/vehicle size & 18 Tare mass (kg) | 19 Total Gross (including tare) (kg) CONTAINER/EHICLE PACKING CERTIFICATE 21 RECEIVING ORGANISATION RECEIPT hereby declare that the goods described above have bee accordance with the applicable provisions. acked/loaded into the container/vehicle identified above i / Received the above number of peckages/containers/trailers in apparent good order and condition unless stated hereon: RECEIVING ORGANISATION MUST BE COMPLETED AND SIGNED FOR ALL REMARKS: FOR PACKING/LOADING. CONTAINERIVEHICLE LOADS BY PERSON RESPONSIBLE 20 Name of company Haulier's name | (OF SHIPPER PREPARING THIS 22 Neme of company NOTE) Name/Status of declarant Vehicle reg no. Name/Status of declarant Place and date Signature and date Place and date Signature of declarant DRIVER'S SIGNATURE Signature of declarant#

Page 5IMO DANGEROUS GOODS DECLARATION 1 Shipper Tesla Motors 2 Transportation Document Number 564403016 45500 Fremont Blvd Fremont, Ca 94538 3 Page 1 of 1 Pages 4 Shipper's Reference 6 Consignee Tesla Automobile Distribution (Beijing) Co. LTD 5 Freight Forwarder's Reference 9 Dongdaqiao Rd. UNIT L1-20 Chaoyang, 010 Beijing, Chaoyang 010 100020 China 7 Carrier (to be declared by the Carrier) I hereby declare that the contents of this consignment are fully and accurately described above by the proper shipping names), and are classified, packaged, marked and SHIPPER'S DECLARATION labeled/placarded, and are in all respects in proper condition for transport according to applicable interational and national governmental regulations. 10 Vessel/Flight and Date 9 Additional Handling Information SEROJA ENAM 435R ETD: 08/30/2014 24 HR Emergency Contact: Chemtec: +1 (703) 527-3837 (International) 11 Port/Place Handling +1 (800) 424-9300 Contract Number CCN204273 (Within the USA) Oakland 14 Shipping Marks Number and Kind of Packages, Description of Goods GW (kg) CUBE (m3) Class 9 2X Vehicles Tesla Model S 4,400 kg 28.06m3 PONU1606826 DC MRKU2672076 HC MRKU3779048 HC MRKU4599652 HC UN3171, Battery-Powered Vehicle, MRKU4871776 HC CLASS 9 MSKU0545074 HC EMS: F-I, S-I Total of 2 Vehicles MSKU1201263 HC 15 CTU ID No. Refer to 7 contai 16 Seal No. in Sec 14' Shirping Marks' lers listed above 17 CTU Size and Type 18 Tare Mass (kg) 40 feet HC CONTAINER/VEHICLE PACKING CERTIFICATE 4,400 (kg) 19 Total Gross Mass (kg) 4,400 (kg) 21 Receiving Organization Receipt I hereby declare that the goods described Received the above number of packages/containers/trailers in apparent good order and condition container/vehicle identified above in above have been packed/loaded into the unless stated hereon: RECEIVING ORGANIZATION REMARKS: accordance with the applicable provisions. 20 Name of Company Hauler's Name Tesla Motors Inc 22 Name of Company Preparing Note Tesla Motors Inc Name/Status of Declarant Dave Michaelson/Logistics MGR Vehicle Registration No. Name/Status of Declarant Dave Michaelson/Logistics MGR Place and Date Fremont, Ca/ August 23, 2014 Driver Name and Date Place and Date Fremont, Ca/ August 23, 2014 Signature of Declarant Driver's Signature Signature of Declarant This document created using Shipping Solutions Professional export software, www.shipsolutions.com.#