ARKEMA Inc. — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation 1200 New Jersey Avenue, SE Pipeline and Hazardous Materials Washington, DC 20590 Safety Administration FEB 1 8 2015 Ms. Christina Kurtz Manager Hazmat Regulations and Packaging ARKEMA Inc. 900 First Avenue King of Prussia, PA 19046-1308 Reference No. 14-0226 Dear Ms. Kurtz: This is in response to your November 28, 2014 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) relating to the orientation of a marine pollutant marking placed on a package. Specifically, you ask if the marking may be placed on a package with the flat sides parallel to the package. While it is the intent of the regulations that the marking be oriented square-on point on a package when possible, the requirements in § 172.322 of the HMR, Part 5;2.4.9 of the International Civil Aviation Organization's Technical Instructions for the Safe Transport of Dangerous Goods (ICAO TI) and Chapter 5.2.1.6 of the International Maritime Dangerous Goods (IMDG) Code do not prohibit the placement of the marking in an orientation where the square-on-point is located with its flat sides parallel to the package. I trust this information is helpful. If you have further questions, please do not hesitate to contact this office. Sincerely, Duane A Phl Duane A. Pfund International Standards Coordinator Standards and Rulemakıng Division#

Page 2... Babich §172.322 (e) Marine Pollutant ARKEMA 14-0226 November 18, 2014 Standards and Rulemaking Division PHMSA U.S. Department of Transportation, East Building 1200 New Jersey Ave. Washington, D.C. 20590-0001 Attention: PHH-10 RE: Interpretation on orientation of marine pollutant marking; §172.322(e) Dear Sir/Madam: With the implementation of GHS in the United States on June 1, 2015, packages will have additional required markings. Thus, it will be a challenge to fit all of the transport and worker safety labeling, pictograms, and markings on the packages. We will be placing the hazard warning labels with the flat sides parallel to the package since there is an interpretation letter (Reference Number 02-0207) stating that it is an acceptable practice. In addition, to help us with this dilemma, we would like to do the same for the marine pollutant mark. Will this be acceptable or must the marine pollutant marking be placed square-on-point (diamond)? Sincerely, Christina M. Kurtz Manager Hazmat Regulations and Packaging ARKEMA Inc. 900 First Ave. King of Prussia, PA 19406-1308 Phone: 610-205-7417 Fax: 610-205-7096 E-mail: Christina.kurtz@arkema.com#