XPO Logistics – Supply Chain — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Avenue, SE Washington, DC 20590 April 1, 2021 Erin Sineath Global Manager of Dangerous Goods XPO Logistics – Supply Chain 4043 Piedmont Parkway High Point, NC 27265 Reference No. 21-0021 Dear Ms. Sineath: This letter is in response to your March 4, 2021, letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the definition of a “different packaging.” Specifically, you indicate that closure instructions for a UN Specification 4G (fiberboard) packaging require the use of “3/16-inch Anti-Static Bubble wrap” for assembly. You ask whether it would be permissible to purchase a bubble wrap from another vender, as long as the same design specifications have been met. The answer is yes. In accordance with § 178.601(c)(4), “a different packaging is one that differs (i.e., is not identical) from a previously produced packaging in structural design, size, material of construction, wall thickness or manner of construction.” Therefore, having the bubble wrap manufactured by a different person does not automatically constitute a different packaging. However, please note that if the bubble wrap differs in design specification, it would constitute a different packaging. I hope this information is helpful. Please contact us if we can be of further assistance. Sincerely, Dirk Der Kinderen Chief, Standards Development Branch Standards and Rulemaking Division#

Page 2Geller 20-0021 From: INFOCNTR (PHMSA) To: Hazmat Interps Subject: FW: Request for Formal Interpretation Date: Friday, March 5, 2021 11:40:19 AM Attachments: DOT Interp ESD Bubble Wrap.pdf Hello, Attached is a request for letter of interpretation. Thanks, Jonathon, HMIC From: Erin Sineath [mailto:Erin.Sineath@xpo.com] Sent: Thursday, March 4, 2021 4:53 PM To: INFOCNTR (PHMSA) <INFOCNTR.INFOCNTR@dot.gov> Subject: Request for Formal Interpretation CAUTION: This email originated from outside of the Department of Transportation (DOT). Do not click on links or open attachments unless you recognize the sender and know the content is safe. Dear Hazmat Info Center, Attached you will find a request for formal interpretation. Thank you in advance for your assistance. Erin N. Sineath Supply Chain Global Manager of Dangerous Goods XPOLogistics 4043 Piedmont Parkway High Point, NC 27265 USA O: +1 336-217-3698 M: +1 336-906-4842#