FedEx — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department 1200 New Jersey Avenue, SE Washington, DC 20590 Pipeline and Hazardous Materials Safety MAR 3 0 2018 Administration Melissa Owens HazMat/Accident Specialist FedEx 1475 Bottler Road Uniontown, OH 44685 Reference No. 17-0126 Dear Ms. Owens: This letter is in response to your November 15, 2017, letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to shipping papers. Specifically, you ask whether a shipping paper must list the quantity and type of packaging for each hazardous material that is placed inside of an overpack. You further ask if the sample shipping paper included with your letter meets the requirements of § 172.202(a)(7) and (c)(1). The number and type of packages must be indicated on a shipping paper either before or after the required basic description as outlined in § 172.202(a)(7) and (c)(1). The type of packages must be indicated as a description of the package (i.e., "12 drums"). Placing packages containing hazardous materials in an overpack would not negate the need to identify the quantity of the hazardous material on a shipping paper. Therefore, the sample shipping paper included with your letter does not meet the HMR requirements. I hope this information is helpful. Please contact us if we can be of further assistance. Sincerely. THen Poster T. Glenn Foster Chief, Regulatory Review and Reinvention Branch Standards and Rulemaking Division#

Page 2andrews §/72.202 (a)(7) Shupping Paper. Dodd, Alice (PHMSA) 7-0126 From: Jones, Breanna CTR (PHMSA) Sent: Tuesday, November 21, 2017 4:58 PM To: Hazmat Interps Subject: FW: Interpretation Letter Request Attachments: FCC PHMSA Interpretation Request.pdf Hello, Please see the attached interp request. Regards, -Breanna From: Melissa Owens [mailto:melissa.mcpherson@fedex.com/ Sent: Monday, November 20, 2017 1:32 PM To: 'phmsa.hm-infocenter@dot.gov' Subject: FW: Interpretation Letter Request Good Afternoon, After speaking with Brianna at your location she requested that we note that we are unsure of whether or not the packing set up is an overpack or an UN-specification outer package. We are requesting some guidance as to when units should be added to the customer's bill of lading when multiple hazards and/or non-hazardous material are shipped inside the same package type (in this case, box). Regards, Melissa From: Melissa Owens Sent: Wednesday, November 15, 2017 2:29 PM Subject: Interpretation Letter Request To: 'phmsa.hm-infocenter@dot.gov' Good Afternoon, Attached is my request for a letter of interpretation. Please let me know if you need any additional information. Regards, Melissa Owens FedEx Custom Critical HazMat / Accident Specialist 1475 Boettler Road Uniontown OH 44685 234.310.4311 1446133@fedex.com 1#

Page 3HazMat / Accident Specialist Melissa Owens 1475 Boettler Road Safety Department Telephone 234.310.4311 Uniontown, OH 44685 1446133@fedex.com Fax 234.310.4130 FedEx Custom Critical November 15, 2017 Mr. Shane Kelley Acting Director, Standards and Rulemaking Division U.S. DOT/PHMSA (PHH-10) 1200 New Jersey Ave, SE East Building, 2nd Floor Washington, DC 20590 Dear Mr. Kelley, I am writing to request a Department of Transportation (DOT) formal letter of interpretation regarding shipping paperwork requirements. Recently a customer submitted a shipper's bill of lading showing one non-hazardous and two basic description is not listed and we do not believe the paperwork example shown below hazardous chemicals in the same overpack. The quantity and type of packaging for each meets the requirements of 172.202(a)(7) and 172.202(c)(1). Units) Pkg HM Description NMFC Class / Wigt (ib) 1 BOX SOLUTIONS, BLOOD ANALYSIS, RELEASED VALUE NOT EXCEEDING 2.66$ PER POUND. 080000-00 60 427.20 × UN1824,Sodium hydroxide solution, 8, I,SOLUTIONS, BLOOD POUND. ANALYSIS, RELEASED VALUE NOT EXCEEDING 2.65$ PER 060000-00 60 101.75 UN1814, Potassium hydroxide, solution,8,lI,SOLUTIONS, BLOOD ANALYSIS, RELEASED VALUE NOT EXCEEDING 060000-00 60 226.55 2.65$ PER POUND. 26 BOX EXCEEDING 2.65$ PER POUND SOLUTIONS, BLOOD ANALYSIS, RELEASED VALUE NOT 060000-00 60 564.52 The customer strongly believes that listing the quantity and type in association with the inner container quantity and type for each basic description. We would appreciate your overpack meets the regulation requirements. As a result they denied our request to list the guidance as to whether or not our interpretation is correct, so we are not unnessarily declining shipments from this customer. Sincerely, Melissa Owens HazMat / Accident Specialist 234.310.4311 1446133@fedex.com#