QSA Global, Inc — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Avenue, SE Washington, DC 20590 MAR 0 6 2018 Lori Podolak Senior RA/QA Specialist QSA Global, Inc. 40 North Avenue Burlington, MA 01803 Reference No. 17-0079 Dear Ms. Podolak: This letter is in response to your July 6, 2017, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the marking of U.S. Department of Transportation (DOT) Specification 7A packagings. You state§ 178.350(b) specifies that packaging conforming to DOT Specification 7 A criteria must be marked with "USA DOT 7 A Type A" and "Radioactive Material." You include in your email a picture of a marking that indicates the proper shipping name, the specification packaging type, and the country of origin; however, the words "Type A Package" are placed in conjunction with the proper shipping name as opposed to being in line with the packaging specification. Specifically, you ask whether it is acceptable to mark a DOT Specification 7 A package in a sequence other than that which appears in the HMR. The answer is no. "USA DOT 7 A Type A" is a given packaging specification that is required to be marked in accordance with§ 178.350(b). The HMR do not permit deviation in words or sequence from that which appears in quotation marks. Additionally, note that the words "Radioactive Material" are no longer required as part of the specification marking. The January 26, 2004, final rule titled "Hazardous Materials Regulations: Compatibility with the Regulations of the International Atomic Energy Agency" (HM-230; 69 FR 3632) removed this requirement since those words appear as part of the proper shipping name (PSN) for all radioactive materials. I hope this information is helpful. Please contact us if we can be of further assistance. Sincerely, /.// ~ // :/,<1/'~ / / ,~ /tf/;£~-h__._ I/ / ,,:f ,//Dirk er Kinderen , Chief, Standards Development Branch Standards and Rulemaking Division#

Page 23176.35€ (b) narkero Dodd, Alice (PHMSA) 17-0077 Sent: INFOCNTR (PHMSA) Thursday, August 03, 2017 9:15 AM To: Dodd, Alice (PHMSA) Subject: FW: Request for Interpretation on Marking Requirements of 49 CFR 178.350(b) Specification 7A Attachments: Interpretation Request Letter 49 CFR 178.350 Marking dated 07062017.pdf From: INFOCNTR (PHMSA) Sent: Friday, July 07, 2017 11:40 AM Subject: FW: Request for Interpretation on Marking Requirements of 49 CFR 178.350(b) Specification 7A To: Hazmat Interps < hazmatinterps@dot.gov> Hi Shante/Alice, Please submit this as a letter of interpretation. Please let me know if you have any questions. Thanks, Jodi From: Podolak, Lori [mailto:Lori.Podolak@qsa-global.comJ To: INFOCNTR (PHMSA) < INFOCNTR.INFOCNTR@dot.gov> Sent: Thursday, July 06, 2017 3:32 PM Subject: Request for Interpretation on Marking Requirements of 49 CFR 178.350(b) Specification 7A Please see the attached request for interpretation letter regarding marking compliance to this section of the regulations. Regards, Lori Podolak Regulatory Affairs/Quality Assurance Department Senior RA/QA Specialist QSA Global, Inc. 30 North Avenue, Burlington, MA 01803 Email: Phone: (781) 505-8241 Lori. Podolak@QSA-Global.com OSA GLOBAL *********************************************************************** This transmission contains information which may be confidential and which may also be privileged. It is intended for the named addressee 1#

Page 3only. Unless you are the named addressee, or authorized to receive it on behalf of the addressee you may not copy or use it, or disclose it to anyone else. If you have received this transmission in error please *********************************************************************** contact the sender. Thank you for your cooperation. For more information about QSA Global Inc. please visit our website at http://www.gsa-global.com#

Page 4QSA Global, Inc. 40 North Avenue Burlington, MA01803 Telephone: (781) 272-2000 Toll Free: (800) 815-1383 Facsimile: (781) 359-9191 6 July 2017 U.S. DOT PHMSA Office of Hazardous Materials Standards ATTN: PHH-10 East Building 1200 New Jersey Avenue, S.E. Washington, D.C. 20590-001 Interpretation Request: Marking Compliance for 49 CFR 178.350(b) Specification 7 A Dear Sir or Madam: QSA Global Inc. requests clarification on formatting of the marking specified in this section of the regulation. As currently stated, the regulation specifies that packaging conforming to the Specification 7 A criteria must be marked with "USA DOT 7 A TYPE A" and "Radioactive Material". Although our packaging contains all the information for this marking, the marking of "TYPE A" is included as part of the proper shipping name on the package, and it is not repeated directly after the marking for "USA DOT 7 A" (see an example as shown on the right). QSA Global has recently been advised that a representative of FedEx considers this formatting to be unacceptable since "USA DOT 7 A TYPE A" does not appear as an uninterrupted sequence on the label. Can you please advise, for compliance purposes to 49 CFR 178.350(b ), whether labeling that incorporates the "TYPE A" wording as part of the package marking when contained in the proper shipping name is acceptable, so long as the rest of the required marking from 49 CFR 178.350(b) is included elsewhere on the Specification 7 A package? If you have any questions or need further clarification regarding this issue, please contact me. Sincerely, e-Signed by Lori Podolak on 2017-07-06 19:30:32 GMT Lori Podolak Senior RA/QA Specialist Regulatory/Health Physics Department Email: Lori.Podolak@gsaglobal.com Ph: (781) 505-8241 ~ NOUf YCIV!L AU IHOfU11£S · lf f OO~D a DONO! H ~"D lE ~ , . • • A DANGER A RADIOACTIVE MATERIAL TYPE A PACKAGE SPECIAL FORM UN3332 USA DOT 7A l&Ol)C.L• 10~ tl'H !QZ tl . ~YOf>C Se-7!1. Co\1",-.CltY J Tl!Q l• I '- QSA GLOBAL INC. BURLINGTON, MA 01803 USA 9 0 I lll#