J.J. Keller and Associates, Inc. — Hazardous Materials Safety Interpretation

Page 10 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Avenue, SE Washington, DC 20590 AUG 2 3 2019 Thomas J. Ziebell Sr. Editor - Hazardous Materials Trans. J.J. Keller and Associates, Inc. P.O. Box 368 Neenah, WI 54957 Reference No. 19-0028 Dear Mr. Ziebell: This letter is in response to your March 12, 2019, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the marking requirements for lithium cells and batteries. Specifically, you ask whether more than one telephone number may be provided on the mark required by§ 173.185(c)(3). You describe a scenario where one telephone number is provided for the domestic transportation portion of a trip and a different telephone number for the international transportation portion. The answer is yes. Section 173 .185( c )(3)(i)(C) does not prohibit including multiple telephone numbers provided each number reaches a person that can provide additional information on the contents of the package. Furthermore, identifying that one number is for domestic purposes and the other number is for international purposes is also not prohibited. I hope this information is helpful. Please contact us if we can be of further assistance.#

Page 2Dodd, Alice (PHMSA) From: Sent: To: Subject: INFOCNTR (PHMSA) Tuesday, March 12, 2019 2:24 PM Hazmat Interps FW: Letter of Interpretation Request Hello Alice and lkeya, Please see the letter of interpretation request below. Lynsie Patschke Transportation Regulatory Specialist Hazardous Materials Information Center (HMIC) From: Ziebell, Thomas (Tom) J [mailto:TZiebell@jjkeller.com] Sent: Tuesday, March 12, 2019 12:42 PM To: INFOCNTR (PHMSA) <INFOCNTR.INFOCNTR@dot.gov> Cc: Atkinson, Michael L <MAtkinson@jjkeller.com>; Ness, Heather L <HNess@jjkeller.com> Subject: Interpretation on 173.185(c)(3)(i)(C) Request for interpretation. I' m requesting an interpretation on the marking requirements in 173.185(c)(3)(i)(C). The text in 173.185(c)(3)(i)(C) reads that the ** must be replaced by a telephone number. I interpret this to mean one telephone number. This was confirmed by Lynsie in the Information Center when we spoke today and she also said there is no written interpretation on this. However, we produce this marking for customers and many want two telephone numbers listed. One number for calls when the package is in the U.S. and the other number for when the package is not in the U.S. Other companies that produce this marking add additional telephone numbers and text so frequently that the industry believes this is in compliance with the regulations. Can two telephone numbers be listed on the marking? If two are allowed, can words such as "For domestic" or "For international" be added to differentiate between the two? Thank you very much for your assistance. Thomae J Ziebell Sr. Editor - Hazardous Materials Trans. P.O. Box 368, Neenah, WI 54957-0368 tziebell@jjkeller.com 1920-722-2848 Ext. 2532 J . J. Keller & Associates , Inc. I JJKeller com Cl fffl 1#

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