Global Logistics — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Avenue, SE Washington, DC 20590 DEC 1 5 2016 Ms. Julie Brown Eastman Chemical Company Global Logistics Principal Distribution Safety Representative 200 S. Wilcox Drive Kingsport, TN 37662-5280 Reference No. 16-0106 Dear Ms. Brown: This letter is in response to your June 16, 2016, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to background marks, such as stitching, on a preprinted marking, label, or placard. You include in your email photographs showing a white bag that has conductive threading throughout, including within a preprinted Class 9 placard and marine pollutant marking. Specifically, you ask whether visible stitching on a Class 9 placard or label prescribed in §§ 172.560(b) and 172.446(b ), respectively, and a marine pollutant marking prescribed in§ 172.322(e), is permitted under the HMR. The answer is yes. In accordance with § 172.322( e )(2), for the marine pollutant marking, the symbol and border must be black on a white or suitable contrasting background. For labels and placards, preprinting is authorized provided the color tolerances in Part 172, Appendix A, Table 3 are met (see§ 172.407(d)(4)(i)(B) and§ 172.519(d)(3)). Therefore, the HMR permit threading to show through the white background of a marking, label, or placard, as pictured on the preprinted bags provided with your letter. I hope this information is helpful. Please contact us if we can be of further assistance. Sincerely, ,,----7~~~ T. Glenn Foster Chief, Regulatory Review and Reinvention Branch Standards and Rulemaking Division#

Page 2l )\cv'2 (\) P /t1 - 'J le r_j(' \ C l AQ {{ rrl Goodall, Shante CTR (PHMSA) From: Sent: To: Subject: Rivera, Jordan CTR (PHMSA) Thursday, June 16, 2016 3:50 PM Hazmat Interps FW: Requesting a formal interpretation Hi Shante/Alice, Please submit this as an interpretation letter. Ms. Brown spoke with Jodi. Please let me know if you have any questions. Thanks, Jordan From: Brown, Julie [mailto:jvbrown@eastman.com] Sent: Thursday, June 16, 2016 1:51 PM To: INFOCNTR (PHMSA) Cc: Slaughter, Shannon C Subject: Requesting a formal interpretation I would like to request a formal interpretation on whether or not the background color of this pictured class 9 placard and marine pollutant mark (partial picture) meet 49CFR back ground colors. The bag is white; however, has conductive threading throughout. We are wondering if the threading interferes with the requirement that the background "must be white for class 9 placards and labels stated in 172.560(b) and 172.446(b) and for background of a marine pollutant marking which "must be white or suitable contrasting background" in 49CFR 172.322 (e). 1#

Page 3Julie Brown Eastman Chemical Company Global Logistics Principal Distribution Safety Representative 200 S. Wilcox Drive Kingsport, TN 37662-5280 423-229-6420 phone 423-361-6420 mobile jvbrown@eastman.com NOTICE: This email message is for the sole use of the intended recipient ( s) and may contain confidential and privileged information. Any unauthorized review, use, disclosure or distribution is prohibited. If you are not the intended recipient, please contact the sender by reply email and destroy all copies of the original message. 2#