Alchem Chemical Company — Hazardous Materials Safety Interpretation

Page 1Alchem Chemical Company 5360 Tulane Drive, SW Atlanta, GA 30336 Reference No. 17-0011 Dear Mr. Johnson: This letter is in response to your January 31, 2017, e-mail and letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to general marking requirements for non-bulk packages. Specifically, you ask if the 12 mm height requirement is applicable to the UN identification number only, or if it applies to both the UN identification number and the proper shipping name. This minimum height requirement for characters on a non-bulk package is applicable to the UN identification number only. According to § 172.301(a), the identification number (preceded by "UN," "NA," or "ID," as appropriate) must be marked in characters at least 12 mm (0.47 inches) high. Note that for non-bulk packages with a capacity of 30 liters (8 gallons) or less, the package shall be marked with characters at least 6mm (0.24 inches) high. The HMR do not specifically prescribe minimum height requirements for the display of the proper shipping name on a non-bulk package. If a non-bulk package displays characters using the minimum 12 mm or 6 mm height requirements as prescribed in § 172.301(a), the proper shipping name may be displayed in the same manner. I hope this information is helpful. Please contact us if we can be of further assistance. Sincerely, Chief, Standards Development Branch Standards and Rulemaking Division#

Page 2Please submit this as a letter of interpretation. I spoke with Mr. Johnson. Please let me know if you have any questions. Thanks, Jordan From: Johnny Johnson (Alchem Chemical [mailto:Johnny.Johnson@alchemchemical.com] Sent: Tuesday, January 31, 2017 1:02 PM To: PHMSA HM InfoCenter <PHMSAHMInfoCenter@dot.gov> Subject: Request for guidance on 172.301 l've attached a request for a letter of interpretation/guidance - Please note I've also sent this by US Mail Service (Our mail from the ind park is sometimes very slow in leaving so please forgive me in double submitting) -- Thanks in advance for any assistance you can provide... Johnny Johnson | JohnnyJ@alchemchemical.com Alchem Chemical Company alchem@alchemchemical.com Ph# 404-696-9202 Fax# 404-696-8207#

Page 3A request for a letter of interpretation in regards to : $ 172.301 As added to the federal register January 2013 with compliance January 2017 General marking requirements for non-bulk packagings. (a) Proper shipping name and identification number. (1) Except as otherwise provided by this subchapter, each person who offers a hazardous material for transportation in a non-bulk packaging must mark the package with the proper shipping name and identification number (preceded by "UN", "NA" or "ID," as appropriate) for the material as shown in the § 172.101 Hazardous Materials Table. The identification number marking preceded by "UN", "NA". , or "ID" as appropriate must be marked in characters at least 12 mm (0.47 inches) high. Packages with a maximum capacity of 30 liters (8 gallons) or less, 30 kg (66 pounds) maximum net mass, or cylinders with a water capacity of 60 liters (16 gallons) or less must be marked with characters at least 6mm (0.24 inches) high. Packages with a maximum capacity of 5 liters (1.32 gallons) or 5 kg (11 pounds) or less must be marked in a size appropriate for the size of the package. After consulting with our local office and some different compliance companies - their seems to be some vague understanding, or let's say a difference in interpretation on what the Font size should be concerning the Shipping Name vs The UN Id Number in regards to this regulation - Whether it only applies to the UN Id number or the whole shipping name including the UN Id -- Some say the Regulation as written only applies to the UN Id # only --- while others tell me the two are synonymous in application.. My company, like most in our industry in an effort to save time, money and reduce human 5360 Tulane Drive SW Atlanta, Georgia 30336 404 696-9202 Fax 404 696-8207#

Page 4a can an a a canes de to mast cats seem to be on both sides or now this regulation is applied. — If you could please clarify whether the 12mm size requirement applies only to the UN Id or both the UN Id and Shipping Name on packages greater than 30 liter's. I've sent a copy of a label for a drum with the Shipping Name at 6mm and UN Id 12mm as you see this takes up a big portion of the label - if the size requirement only applies to the UN Id only it would certainly aid in label generation and efficiency in marking a package. Thanks in advance for your help, in helping me and my company in understand the application of this particular regulation. Best Regards Johnny Johnson Alchem Chemical Co 5360 Tulane Dr. SW Atlanta GA 30336 404-696-9202 5360 Tulane Drive SW Atlanta, Georgia 30336 404 696-9202 Fox 404 696-8207#

Page 5persists: Get effects. Lot# ts and container in ed clothing. Wash ational and international cautiously with water for N: Wash with plenty of ands thoroughly after ses, if present and easy to If skin irritation occurs: Get face protection. Avoid Safety Data Sheet prior to use. No. Marine Pollutant Ethoxylate) Environmentally Hazardous Date CAS 127087-87-0 UN3082 stance, liquid n.o.s (Nonylphenol, (Surfonic® N-40, N-40, NP4) Surfactant N-40 Empty Container. FOR CHEMICAL ASSISTANCE CALL CHEMTREC - 800-424-9300 Industrial Use Only. Do Not Weld or Cut on OTECTION REACTIVITY FLAUMABL ITY HEALTH Chamical Distributors Motons Agar 2tpm naca N#