Lockheed Martin Space Systems Compnay, SWFLANT — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation 1200 New Jersey Avenue, SE Washington, D.C. 20590 Pipeline and Hazardous Materials Safety Administration MAR 0 6 2015 Ms. Amanda B. Foskey Mechanical Engineer Asc.-ICCB Lockheed Martin Space Systems Company, SWFLANT Kings Bay, GA 31547 Ref. No. 14-0204 Dear Ms. Foskey: This responds to your June 26, 2014 email requesting clarification of the labeling requirements in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you request clarification on proper labeling of your package containing a Division 1.4B explosive. In your email, you describe a combination packaging containing Division 1.4B explosive materials consisting of a sealed jar, inner packaging placed in a folding paperboard box outer packaging. You then overpack the individual packages in a larger fiberboard box for shipment. It is your understanding that the outer fiberboard box (i.e., the overpack) must be labeled with the Division 1.4B explosive label. However, you ask if you are required to label the outer paperboard boxes that the jars are packed in as well as the jars themselves? Additionally, you ask if there is any instance where using an explosive label smaller than the dimensions specified in § 172.407(c) is acceptable? Your understanding is correct. Section 173.25(a)(2) requires an overpack to be labeled, unless the labels representative of the hazardous material in the overpack are visible. Therefore, because the paperboard boxes placed in the fiberboard box overpack are not visible, the tiberboard box must be labeled. Additionally, the outer packaging of a combination packaging must be labeled in accordance with §172.400(a). However, the inner packagings of combination packagings are not required to be labeled. Thus, the sealed jar that the Division 1.4B explosive is contained in is not required to be labeled. Finally, the label is required to be a minimum of 100mm × 100mm in accordance with § 172.407 unless labeling in accordance with authorized international standards that allow label size modifications. I hope this answers your inquiry. If you need additional assistance, please contact this Office at 202-366-8553. Sincerely. Till Fikee Dirk Der Kinderen Acting Chief, Standards Development Branch Standards and Rulemaking Division#

Page 2Boothe §172.4076) Dodd, Alice (PHMSA) Labelers From: Ciccarone, Michael CTR (PHMSA) Sent: To: Hazmat Interps Monday, October 27, 2014 1:52 PM Subject: FW: Request Letter of Interpretation - Hazardous Material Labeling Shante/Alice, What's the status of this interp request? I don't see it in the database. Thanks, Mike From: INFOCNTR (PHMSA) Sent: Friday, June 27, 2014 2:37 PM To: Hazmat Interps Subject: FW: Request Letter of Interpretation - Hazardous Material Labeling This caller definitely wants this letter submitted as a formal letter of interpretation. She has already spoken with Adam Lucas in the Info Center extensively on this issue. -Victoria From: Foskey, Amanda B [mailto:amanda.b.foskey@lmco.com] To: INFOCNTR (PHMSA) Sent: Friday, June 27, 2014 10:00 AM Cc: Bailey, Donna J; Febles, Javier A; Higginbotham, Roy A; Brazell, Sonya P; Haslip, Gary M; Welborn, Jim H Subject: Request Letter of Interpretation - Hazardous Material Labeling Good morning, This is a forward of an email 1 sent yesterday regarding hazardous material labeling. I just spoke with a gentleman over the phone and was informed that I need to annotate in the email that I am seeking a Letter of Interpretation. When I spoke with the gentleman on the phone this morning, he confirmed what another gentleman stated yesterday - that the paperboard box that the jar is packaged in and the fiberboard box that the individual boxes are overpacked in require the explosive labels and that they are required to be a minimum of 100mmX100mm; however, the jar that the explosive is packaged in does not require an explosive label. I would like a written response confirming the above interpretation. Thank you for your assistance, Amanda Foskey 402K2EB Mechanical Engineer Asc. - ICCB Lockheed Martin Space Systems Company SWFLANT - Kings Bay, Ga (912)573-9897 1#

Page 3From: Foskey, Amanda B Sent: Thursday, June 26, 2014 5:02 PM To: infocntr@dot.gov Subject: Hazardous Material Labeling Cc: Bailey, Donna J; Febles, Javier A (javier.a.febles@lmco.com); Higginbotham, Roy A; Brazell, Sonya P Good evening, I am seeking clarification on what is required regarding the labeling of 1.4 "B" explosive materials. We package the 1.4 "B" explosive materials in a sealed jar, which is in turn packaged in a folding paperboard box (see figure below). The combination pack of the jar and the paperboard box are POP tested. We then overpack the individual packages in a larger fiberboard container for shipment. I have read through Part 172.400 - General Labeling Requirements, of 49 CFR but would like clarification on which containers actually require the explosive labeling. I understand we are required to place the explosive label on the outside of the fiberboard box that the explosives are packaged in, but are we required to place the explosive labels on the inner paperboard boxes that the jars are packaged in? And are we required to label the jars that the explosive is physically packaged in? Additionally, is there any instance where using an explosive label smaller than the dimensions specified in Part 172.407(c) is acceptable for use? Thank you for your assistance, Amanda Foskey Amanda 8. Posey england Mechanical Engineer Asc. - ICCB Lockheed Martin Space Systems Company SWFLANT - Kings Bay, Ga (912)573-9897#