Uniweld Products, Inc. — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Plpellne and Hazardous Materials Safety Administration JAN 3 0 2020 1200 New Jersey Avenue, SE Washington, DC 20590 Janet Beets Uniweld Products, Inc. 2850 Ravenswood Road Fort Lauderdale, FL 33312 Reference No. 19-0089 Dear Ms. Beets: This letter is in response to your June 20, 2019, letter and August 28, 2019, phone conversation requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to marking requirements. Specifically, you provide an example of the markings on a strong outer packaging in reference to the following scenario: • Uniweld Products, Inc. offers propane and propylene for transportation in DOT specification 39, non-refillable steel cylinders, further packaged in a strong outer packaging (as required in DOT Special Permit (DOT-SP) 13318). • The packaging configuration is either 24 propylene cylinders, 24 propane cylinders, or 12 propylene and 12 propane cylinders. • The packages ate only transported via highway. • The strong outer packaging is marked with the following: "IMO 2.1," "Inside Packages Comply with DOT.SP 13318," "OVERPACKED," "UN 1075 Petroleum Gases Liquified," and "UN 1077 Propylene." Furthermore, there are check boxes next to "UN 1075 Petroleum Gases Liquified" and "UN 1077 Propylene" that will be checked- off based on the presence of the material in the outer packaging. We have paraphrased and answered your questions as follows: Q 1. You ask whether the strong outer packaging may display a check box next to both "UN1075, Petroleum Gases Liquefied" and "UN1077, Propylene" for purposes of indicating the presence of one or both hazardous materials. Al. The answer is no. In accordance with§ 172.303(a), no person may offer for transportation a package that is marked with the proper shipping name, the UN identification number of a hazardous material, or any other markings indicating that the material is hazardous unless the package contains the identified hazardous material or its residue. Therefore, when the package contains only propylene or only propane, the package may not display the UN identification number and proper shipping name of the#

Page 2Q2. A2. Q3. A3. Q4. A4. hazardous material that is not present in the package. If both UN identification numbers and proper shipping names are pre-printed on the strong outer packaging, the UN identification number and proper shipping name of the hazardous material not present in the package must be securely covered or voided in some manner to avoid confusion that the material is present. You ask whether the strong outer packaging may display the text"IMO 2.1." The answer is yes. Please note that the HMR does not require the hazard classification (i.e., 2.1) to be marked on the packaging. However, an indication of the International Maritime Organization (IMO) classification may cause confusion or frustration of your shipment in transportation. More specifically, "IMO" may be perceived as an indication that your package is prepared for vessel transportation in accordance with the International Maritime Dangerous Goods (IMDG) Code. You ask whether the strong outer packaging may display the text "INSIDE PACKAGES COMPLY WITH DOT.SP 13318." The answer is no. Paragraph 7.b.(3) of DOT-SP 13318 requires the outside of each outer packaging be marked "Inside package conforms to DOT-SP 13318." Since the text provided in your request differs from the required text in the special permit, the marking does not comply with the conditions of the special permit. The package should be marked with the text as directed in DOT-SP 13318. You ask whether the strong outer packaging may display the text "OVERPACKED." The answer is no. Section 171.8 of the HMR defines an overpack to mean ''an enclosure that is used by a single consignor to provide protection or convenience in handling of a package or to consolidate two or more packages." Because DOT-SP 13 318 requires the use of a strong outer packaging (see paragraph 7.b.(1)), the marked packaging in your request does not meet the definition of an overpack. Therefore, "OVERP ACKED" is not an appropriate marking for your shipment.#

Page 3Please note that if your outer packaging met the definition of an overpack, the word "OVERP ACK" is required to be marked on the outside of an overpack when specification packaging is required, unless the required marking representative of each package type contained in the overpack is visible from outside of the overpack (see§ 173.25(a)(4)). The addition of the "-ED" at the end of the word "OVERP ACK" is not authorized. I hope this information is helpful. Please contact us if we can be of further assistance. Sincerely, e · d n ef, Stand ds Development Branch Standards and Rulemaking Division#

Page 4l . . , -· .. ,.,: i•, , ~W~,, UNIWELDPRODUC1',INC -.;.::::-..::::;;.a 2850 Ravenswood Road, Fort Lauderdale, FL 33312 U.S.A.· 954.584.2000 · 800.323.2111 ~ ~ Fax: 954.587.0109 www.uniweld.com June 20, 2019 RECEIVED JUL O 11019 6.~ " / f ,: Office of Hazardous Materials Initiatives and Training 1200 New Jersey Avenue, SE PHH-SO Washington DC 20590-0001 Re: Hazardous Material Shipping Cartons Question, Uriiweld Products Inc I contacted the Info line for clarification and they advised to write. I have researched this matter but we are seeking clarification as Uniweld wishes to remain in compliance. Uniweld Products is expforing the possibility of changing the cartons that are currently used to ship DOT specification 39, non-refillable steel cylinders. The new,.boxes would have both Propane and Propylene stenciled on the outside with the UN#, Dot-SP 13318, and IMO#. A checkmark would be entered next to the type of cylinders being transported. (Enclosure) either Propane or Propylene or both propane and propylene. Uniweld would have one box to carry 24 propylene, or 24 propane or 12 propane and 12 propylene. An inquiry has been made to FedEx and UPS. They state that some companies do this, but could not tell us if this is in compliance. Looking forward to your reply. 6eets . Decto~~ e~ellence in manufacturing since1949#

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