{"operation":"document","citation":"22-0046","title":"Entegris Inc. — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2022-08-22","effective_on":null,"summary":"22-0046 response to Entegris Inc. concerning 173.202, 173.25.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-22-0046.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-22-0046.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-22-0046","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/standards-rulemaking/hazmat/interpretations/76736/220046.pdf","body":"<<>>\n\n1200 New Jersey Avenue, SE\nWashington, DC 20590\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\nAugust 22, 2022\nJim McManus\nEntegris Inc.\n7 Commerce Drive\nDanbury, CT 06810\nReference No. 22-0046\nDear Mr. McManus:\nThis letter is in response to your April 21, 2022, letter requesting clarification of the Hazardous\nMaterials Regulations (HMR; 49 CFR Parts 171-180) applicable to shipping paper and hazard\ncommunication requirements. You describe a package that is intended for transport by cargo\nonly aircraft containing a Division 4.2 hazardous material, “UN2881, Metal catalyst, dry, 4.2, PG\nII,” covered under DOT Special Permit (DOT-SP) 11447 and Competent Authority Approval\n(CA1995070006). You further describe the package as a gas purification system that consists of\ntwo non-DOT specification stainless steel pressure vessels—though the contents are not under\npressure subject to the HMR—with component parts (e.g., piping), and a welded steel frame to\nsecure the pressure vessels. You seek clarification on how to properly describe on the shipping\npaper the type of package and the quantity of material contained in the pressure vessels, and how\nto properly mark and label the assembled package.\nIt is the shipper’s responsibility to properly classify and describe a hazardous material and\nprovide the required hazard communication, such as shipping paper information, in accordance\nwith Part 172 of the HMR, to alert emergency response personnel to the presence, form and\nmanner of hazardous materials offered into transportation. For instance, the HMR require the\ntotal net mass per package and the number and type of package(s) be indicated on the shipping\npaper. However, the unique circumstances of the containment device in DOT-SP 11447—i.e., a\ngas purification system—makes it more difficult to describe than a standalone package (e.g., a\ndrum). PHMSA notes that both DOT-SP 11447 and CA1995070006 provide details about the\nhazardous material, the package, and the transport requirements—and that the special permit is\nrequired to accompany the shipment and be given to the air carrier. Finally, PHMSA also notes\nthat for purposes of hazard communication, the HMR require that packages placed in overpacks\nhave markings and labels displayed on the overpack unless otherwise visible. See\n§§ 172.202(a)(6) and (7), and 173.25(a)(2), respectively.\n\n<<>>\n\nGiven this information, it is the opinion of this Office that all three examples that you provided\nregarding the description of the quantity and type of package are acceptable under the HMR.\nHowever, the indication of “pressure vessels” when described on a shipping paper may be\nmisunderstood as containing contents under pressure subject to specific HMR requirements.\nFurther, it is acceptable to place the required marking and labeling on the exterior of the gas\npurification system—such as an access panel door—with the understanding that this will be\nobscured by the wooden crate overpack, thus requiring the overpack to also have the required\nmarking and labeling displayed.\nI hope this information is helpful. Please contact us if we can be of further assistance.\nSincerely,\nDirk Der Kinderen\nChief, Standards Development Branch\nStandards and Rulemaking Division\n\n<<>>\n\nBaker\n22-0046\nFrom: INFOCNTR (PHMSA)\nTo: Hazmat Interps\nSubject: FW: Entegris Request for Interpretation\nDate: Thursday, May 5, 2022 1:27:00 PM\nAttachments: image001.png\nimage002.png\nEntegris Request for Interpretation - DOT-SP 11447.pdf\nEntegris Request for Interpretation - DOT-SP 11447-Redacted Version.pdf\nSee attached/below request for interpretation.\nThanks,\nJonathon, HMIC\nFrom: Jim McManus \nSent: Thursday, April 21, 2022 4:56 PM\nTo: INFOCNTR (PHMSA) \nCc: Nicks, Michael (PHMSA) ; Stefanie Reichel ;\nAaron Zagala \nSubject: Entegris Request for Interpretation\nCAUTION: This email originated from outside of the Department of Transportation (DOT). Do not\nclick on links or open attachments unless you recognize the sender and know the content is safe.\nDear Standards and Rulemaking Division:\nPursuant to 49 CFR § 105.20, this letter is being submitted to PHMSA to request a formal letter of\ninterpretation in order to clarify several questions Entegris, Inc. has related to the Hazardous Materials\nRegulations (HMR) and the International Civil Aviation Organization’s Technical Instructions for the Safe\nTransport of Dangerous Goods by Air (ICAO TI). More specifically, the questions pertain to shipments of\npackages covered under DOT-SP 11447 and Competent Authority Approval CA1995070006 by cargo only\naircraft.\nAs this letter includes information of a proprietary nature (e.g. trade secrets), Entegris is requesting\nconfidential treatment in accordance with 49 CFR § 105.30 and has provided a second copy of this letter\nwith the confidential information redacted.\nRegards,\nJim\nJim McManus\nSr. Principal Engineer\nDangerous Goods Safety Advisor (DGSA)\nM 203-482-1606\nT 203-207-9307\nE jim.mcmanus@entegris.com\n\n<<>>\n\nEntegris | PURE ADVANTAGE\n7 Commerce Drive\nDanbury, CT 06810 USA\nCONFIDENTIALITY NOTICE: The contents of this email message and any attachments are intended solely for the addressee(s) and\nmay contain confidential and/or privileged information and may be legally protected from disclosure. If you are not the intended\nrecipient of this message or their agent, or if this message has been addressed to you in error, please immediately alert the sender\nby reply email and then delete this message and any attachments. If you are not the intended recipient, you are hereby notified that\nany use, dissemination, copying, or storage of this message or its attachments is strictly prohibited.\nENTEGRIS PROPRIETARY AND CONFIDENTIAL – INTERNAL\n\n<<>>\n\nSpecialty Gas and Engineered Materials\n7 Commerce Drive\nDanbury, CT 06810\n800.766.2681 Toll-Free\n203.794.1100 Direct\nwww.entegris.com\nApril 21, 2022\nStandards and Rulemaking Division\nPipeline and Hazardous Materials Safety Administration, Attn: PHH-10\nU.S. Department of Transportation\nEast Building\n1200 New Jersey Avenue, SE\nWashington, DC 20590-0001\ninfocntr@dot.gov\nRe: Request for Interpretation\nDear Standards and Rulemaking Division:\nPursuant to 49 CFR § 105.20, this letter is being submitted to PHMSA to request a formal letter of\ninterpretation in order to clarify several questions Entegris, Inc. has related to the Hazardous Materials\nRegulations (HMR) and the International Civil Aviation Organization’s Technical Instructions for the Safe\nTransport of Dangerous Goods by Air (ICAO TI). More specifically, the questions pertain to shipments of\npackages covered under DOT-SP 11447 and Competent Authority Approval CA1995070006 by cargo only\naircraft.\nThis request is a result of discussions I have had with Mr. Michael Nicks of the General Approvals and\nPermits Division, PHH-13, who advised me to submit a formal request for interpretation to address the\nquestions Entegris has raised.\nAs this letter includes information of a proprietary nature (e.g. trade secrets), Entegris is requesting\nconfidential treatment in accordance with 49 CFR § 105.30 and has provided a second copy of this letter\nwith the confidential information redacted.\nBackground\nDOT-SP 11447 is a special permit granted to Entegris, Inc. (formerly Saes Pure Gas, Inc.) which authorizes\nthe transport in commerce of a “Gas Purification System” containing certain Division 4.1 (flammable\nsolids) and 4.2 (spontaneously combustible solids) materials in non-DOT specification stainless steel\npressure vessels.\nDOT-SP 11447 authorizes several exemptions from the HMR as described in Section 4 of the special\npermit, and are summarized as follows:\n• non-DOT specification stainless steel pressure vessels are authorized as a packaging.\n• The maximum quantities for UN 2881, PG II and UN 3089, PG II listed in column 9B of the\nHazardous Materials Table may be exceeded.\n• The materials are not subject to the “away from” segregation requirement in § 176.83 for the\nstorage of Division 4.1 and 4.2 materials in the same cargo hold.\nCA1995070006 is a United States Competent Authority Approval granted to Entegris, Inc. This approval\nserves as an “exemption” as defined in Part 1, paragraph 3.1.1 of the ICAO TI and in Chapter 7.9, Section\n7.9.2 of the IMDG Code and as a “Competent Authority Approval” as defined in 49 CFR § 107.1.\nCA1995070006 is used in conjunction with DOT-SP 11447 for international shipments by air and vessel.\nCA1995070006 waives several requirements of the ICAO TI and IMDG Code when offering for\n\n<<>>\n\ntransportation in commerce certain Division 4.1 and Division 4.2 solids in non-DOT specification stainless\nsteel pressure vessels that conform to the requirements of DOT-SP 11447.\nThis request for interpretation seeks to clarify how the quantity and type of packaging should be\ndescribed on the shipping paper when transporting the DOT-SP 11447 packages by cargo only aircraft.\nThe requirements for the description of the quantity and type of packaging on the shipping paper are\nspecified in 49 CFR § 172.202 and ICAO TI 4.1.5.\nHow should the packaging specified in DOT-SP 11447 be described on the shipping paper?\nEntegris has received several differing interpretations on how the DOT-SP 11447 packaging should be\ndescribed on the shipping paper. The packaging description should align with the regulatory definitions\nof packaging:\nRegulatory Definitions for Packaging:\n49 CFR § 171.8 defines Packaging as follows:\n“means a receptacle and any other components or materials necessary for the receptacle to perform\nits containment function in conformance with the minimum packing requirements of this\nsubchapter.”\nThe ICAO TI defines Packaging as follows:\n“One or more receptacles and any other components or materials necessary for the receptacles to\nperform their containment and other safety functions.”\nPackaging Specified in DOT-SP 11447 and CA1995070006:\nDOT-SP 11447 states the detailed packaging requirements in paragraph 7.a. for the Division 4.2 material\nand paragraph 7.b. for the Division 4.1 material. The following is the packaging description given in DOT-\nSP 11447 for the Division 4.2 material:\nCA1995070006 describes the prescribed packaging in paragraph 5.b. as follows:\nPage 2\n\n<<>>\n\nExample DOT-SP 11447 Package for Division 4.2 Material:\nThe questions Entegris has are based on the following DOT-SP 11447 package:\nNote: See Annex 1 & 2, which include drawings and pictures of the example DOT-SP 11447 package.\nThe example DOT-SP 11447 package is a “Gas Purification System” with the packaging being that\ndescribed in paragraph 7.a. of DOT-SP 11447, containing 60 Kg of UN 2881 − Metal catalyst, dry − PG II,\nequally divided by mass in two (2) non-DOT specification stainless steel pressure vessels under a nitrogen\nblanket not exceeding 25 psig, and with the pressure vessels and associated components arranged and\nsecurely affixed within a welded steel frame as shown in drawings on file with OHMSAPD. The pressure\nvessels are designed, constructed and tested in accordance with Section VIII of the ASME Boiler and\nPressure Vessel Code. The maximum allowable working pressure of the pressure vessels is not less than\n225 psig at 250 °C.\nThis entire “Gas Purification System” is encapsulated inside several bags, including a non-transparent\nmoisture barrier bag (e.g. Mylar) and then further packed in a strong wooden crate to protect the “Gas\nPurification System” from environmental and cosmetic damage during shipment and to form one handling\nunit for convenience of handling and storage. This wooden crate is not specified as a requirement in the\nspecial permit. Entegris considers this wooden crate to be an overpack for the packaging described in\nparagraph 7.a. of the special permit.\nFor the above DOT-SP 11447 example package, Entegris has received several interpretations from other\nexpert parties as to how the packaging should be described on the shipping paper. The interpretations\nare as follows:\n• Interpretation 1: The packaging is two (2) non-DOT specification stainless steel pressure vessels.\nAn aircraft operator has suggested this description, using the term “cylinder” to describe the\npressure vessels, as cylinders is listed as a single packaging in packing instruction 473. This\ninterpretation may be based on the packaging description given in CA1995070006, which states\nthe packagings are non-DOT specification stainless steel pressure vessels.\n• Interpretation 2: The packaging is all materials and components listed in paragraph 7.a. of DOT-\nSP 11447, including; the non-DOT specification stainless steel pressure vessels under a nitrogen\nblanket not exceeding 25 psig, with the pressure vessels and associated components arranged\nand securely affixed within a welded steel frame. (This description adds significant complexity to\nthe shipping paper description and may cause shipment delays)\nSince conflicting interpretations have been provided by several experts, Entegris requests PHMSA to\nclarify which items listed in paragraph 7.a. constitutes the packaging and how the quantity and type of\npackaging should be described on the shipping paper when shipped by air.\nMarking and Labelling Questions:\nAdditionally, there is a concern as to where the marking and labels required by the HMR and the ICAO TI\nshould be placed.\nThe HMR states that markings must be printed on or affixed to the surface of a package or on a label, tag,\nor sign and § 172.406 states labels must be printed on or affixed to the surface of a package or on a label,\ntag, or sign. The ICAO TI has similar requirements for the location of marks and labels.\nAnnex 2 shows pictures of the example purification system. After the system is fully assembled, the\npressure vessels are not visible as they are covered with heating jackets and are also obscured by the\nmetal doors affixed to the welded steel frame.\nFrom a practical standpoint it seems the best location for the marks and labels would be on an external\nsurface of the gas purification system, such as the front doors as shown in the example in Annex 2.\nPage 3\n\n<<>>\n\nQuestions:\n1. For the example DOT-SP 11447 package, which of the following components comprise the\npackaging?\na. two (2) non-DOT specification stainless steel pressure vessels\nb. Nitrogen blanket not exceeding 25 psig\nc. Associated components (e.g. piping, valves and fittings)\nd. Welded steel frame\n2. Assuming Interpretation 1 is correct and only the two (2) non-DOT specification stainless steel\npressure vessels comprise the packaging, is the following description (highlighted in yellow) of\nthe quantity and type of packaging acceptable for shipment by air?\n3. Assuming Interpretation 1 is correct, where should the labels and marks required by Part 172\nsubpart F and E be affixed?\nNote: Due to the design of the gas purification system, the surface of the pressure vessels are not\nvisible as they are covered with heating jackets which cannot be removed for transport. Entegris\nsuggests the marks be placed as shown in the picture in Annex 2.\n4. Assuming Interpretation 2 is correct and all 4 items listed in Question 1 comprise the packaging,\nwhich of the following descriptions of the quantity and type of packaging are acceptable:\nInterpretation 2 − Description for quantity and type of packaging − Option 1\nInterpretation 2 − Description for quantity and type of packaging − Option 2\nPage 4\n\n<<>>\n\nIf both of the above options are incorrect, Entegris would appreciate PHMSA’s guidance on what the\nappropriate description of the quantity and type of packaging is.\n5. Assuming Interpretation 2 is correct, where should the labels and marks required by Part 172\nsubpart F and E be affixed? (Refer to Annex 2 for pictures showing different locations labels and\nmarks can be affixed to)\nEntegris greatly appreciates PHMSA’s attention to this matter and looks forward to a response that further\nclarifies our understanding of the Hazardous Materials Regulations.\nShould PHMSA require additional information to process the interpretation, please contact me at your\nconvenience.\nSincerely,\nJames (Jim) V. McManus\nSr. Principal Engineer\nDangerous Goods Safety Advisor (DGSA)\nEntegris Inc.\nMobile Phone: 203-482-1606\nPage 5\n\n<<>>\n\nThis page includes confidential information\nAnnex 1\nDrawing for Example Gas Purification System\nPage 6\n\n<<>>\n\nThis page includes confidential information\nAnnex 2\nPictures of Gas Purification System\nPage 7\n\n<<>>\n\nSpecialty Gas and Engineered Materials\n7 Commerce Drive\nDanbury, CT 06810\n800.766.2681 Toll-Free\n203.794.1100 Direct\nwww.entegris.com\nApril 21, 2022\nStandards and Rulemaking Division\nPipeline and Hazardous Materials Safety Administration, Attn: PHH-10\nU.S. Department of Transportation\nEast Building\n1200 New Jersey Avenue, SE\nWashington, DC 20590-0001\ninfocntr@dot.gov\nRe: Request for Interpretation\nDear Standards and Rulemaking Division:\nPursuant to 49 CFR § 105.20, this letter is being submitted to PHMSA to request a formal letter of\ninterpretation in order to clarify several questions Entegris, Inc. has related to the Hazardous Materials\nRegulations (HMR) and the International Civil Aviation Organization’s Technical Instructions for the Safe\nTransport of Dangerous Goods by Air (ICAO TI). More specifically, the questions pertain to shipments of\npackages covered under DOT-SP 11447 and Competent Authority Approval CA1995070006 by cargo only\naircraft.\nThis request is a result of discussions I have had with Mr. Michael Nicks of the General Approvals and\nPermits Division, PHH-13, who advised me to submit a formal request for interpretation to address the\nquestions Entegris has raised.\nAs this letter includes information of a proprietary nature (e.g. trade secrets), Entegris is requesting\nconfidential treatment in accordance with 49 CFR § 105.30 and has provided a second copy of this letter\nwith the confidential information redacted.\nBackground\nDOT-SP 11447 is a special permit granted to Entegris, Inc. (formerly Saes Pure Gas, Inc.) which authorizes\nthe transport in commerce of a “Gas Purification System” containing certain Division 4.1 (flammable\nsolids) and 4.2 (spontaneously combustible solids) materials in non-DOT specification stainless steel\npressure vessels.\nDOT-SP 11447 authorizes several exemptions from the HMR as described in Section 4 of the special\npermit, and are summarized as follows:\n• non-DOT specification stainless steel pressure vessels are authorized as a packaging.\n• The maximum quantities for UN 2881, PG II and UN 3089, PG II listed in column 9B of the\nHazardous Materials Table may be exceeded.\n• The materials are not subject to the “away from” segregation requirement in § 176.83 for the\nstorage of Division 4.1 and 4.2 materials in the same cargo hold.\nCA1995070006 is a United States Competent Authority Approval granted to Entegris, Inc. This approval\nserves as an “exemption” as defined in Part 1, paragraph 3.1.1 of the ICAO TI and in Chapter 7.9, Section\n7.9.2 of the IMDG Code and as a “Competent Authority Approval” as defined in 49 CFR § 107.1.\nCA1995070006 is used in conjunction with DOT-SP 11447 for international shipments by air and vessel.\nCA1995070006 waives several requirements of the ICAO TI and IMDG Code when offering for\n\n<<>>\n\ntransportation in commerce certain Division 4.1 and Division 4.2 solids in non-DOT specification stainless\nsteel pressure vessels that conform to the requirements of DOT-SP 11447.\nThis request for interpretation seeks to clarify how the quantity and type of packaging should be\ndescribed on the shipping paper when transporting the DOT-SP 11447 packages by cargo only aircraft.\nThe requirements for the description of the quantity and type of packaging on the shipping paper are\nspecified in 49 CFR § 172.202 and ICAO TI 4.1.5.\nHow should the packaging specified in DOT-SP 11447 be described on the shipping paper?\nEntegris has received several differing interpretations on how the DOT-SP 11447 packaging should be\ndescribed on the shipping paper. The packaging description should align with the regulatory definitions\nof packaging:\nRegulatory Definitions for Packaging:\n49 CFR § 171.8 defines Packaging as follows:\n“means a receptacle and any other components or materials necessary for the receptacle to perform\nits containment function in conformance with the minimum packing requirements of this\nsubchapter.”\nThe ICAO TI defines Packaging as follows:\n“One or more receptacles and any other components or materials necessary for the receptacles to\nperform their containment and other safety functions.”\nPackaging Specified in DOT-SP 11447 and CA1995070006:\nDOT-SP 11447 states the detailed packaging requirements in paragraph 7.a. for the Division 4.2 material\nand paragraph 7.b. for the Division 4.1 material. The following is the packaging description given in DOT-\nSP 11447 for the Division 4.2 material:\nCA1995070006 describes the prescribed packaging in paragraph 5.b. as follows:\nPage 2\n\n<<>>\n\nExample DOT-SP 11447 Package for Division 4.2 Material:\nThe questions Entegris has are based on the following DOT-SP 11447 package:\nNote: See Annex 1 & 2, which include drawings and pictures of the example DOT-SP 11447 package.\nThe example DOT-SP 11447 package is a “Gas Purification System” with the packaging being that\ndescribed in paragraph 7.a. of DOT-SP 11447, containing 60 Kg of UN 2881 − Metal catalyst, dry − PG II,\nequally divided by mass in two (2) non-DOT specification stainless steel pressure vessels under a nitrogen\nblanket not exceeding 25 psig, and with the pressure vessels and associated components arranged and\nsecurely affixed within a welded steel frame as shown in drawings on file with OHMSAPD. The pressure\nvessels are designed, constructed and tested in accordance with Section VIII of the ASME Boiler and\nPressure Vessel Code. The maximum allowable working pressure of the pressure vessels is not less than\n225 psig at 250 °C.\nThis entire “Gas Purification System” is encapsulated inside several bags, including a non-transparent\nmoisture barrier bag (e.g. Mylar) and then further packed in a strong wooden crate to protect the “Gas\nPurification System” from environmental and cosmetic damage during shipment and to form one handling\nunit for convenience of handling and storage. This wooden crate is not specified as a requirement in the\nspecial permit. Entegris considers this wooden crate to be an overpack for the packaging described in\nparagraph 7.a. of the special permit.\nFor the above DOT-SP 11447 example package, Entegris has received several interpretations from other\nexpert parties as to how the packaging should be described on the shipping paper. The interpretations\nare as follows:\n• Interpretation 1: The packaging is two (2) non-DOT specification stainless steel pressure vessels.\nAn aircraft operator has suggested this description, using the term “cylinder” to describe the\npressure vessels, as cylinders is listed as a single packaging in packing instruction 473. This\ninterpretation may be based on the packaging description given in CA1995070006, which states\nthe packagings are non-DOT specification stainless steel pressure vessels.\n• Interpretation 2: The packaging is all materials and components listed in paragraph 7.a. of DOT-\nSP 11447, including; the non-DOT specification stainless steel pressure vessels under a nitrogen\nblanket not exceeding 25 psig, with the pressure vessels and associated components arranged\nand securely affixed within a welded steel frame. (This description adds significant complexity to\nthe shipping paper description and may cause shipment delays)\nSince conflicting interpretations have been provided by several experts, Entegris requests PHMSA to\nclarify which items listed in paragraph 7.a. constitutes the packaging and how the quantity and type of\npackaging should be described on the shipping paper when shipped by air.\nMarking and Labelling Questions:\nAdditionally, there is a concern as to where the marking and labels required by the HMR and the ICAO TI\nshould be placed.\nThe HMR states that markings must be printed on or affixed to the surface of a package or on a label, tag,\nor sign and § 172.406 states labels must be printed on or affixed to the surface of a package or on a label,\ntag, or sign. The ICAO TI has similar requirements for the location of marks and labels.\nAnnex 2 shows pictures of the example purification system. After the system is fully assembled, the\npressure vessels are not visible as they are covered with heating jackets and are also obscured by the\nmetal doors affixed to the welded steel frame.\nFrom a practical standpoint it seems the best location for the marks and labels would be on an external\nsurface of the gas purification system, such as the front doors as shown in the example in Annex 2.\nPage 3\n\n<<>>\n\nQuestions:\n1. For the example DOT-SP 11447 package, which of the following components comprise the\npackaging?\na. two (2) non-DOT specification stainless steel pressure vessels\nb. Nitrogen blanket not exceeding 25 psig\nc. Associated components (e.g. piping, valves and fittings)\nd. Welded steel frame\n2. Assuming Interpretation 1 is correct and only the two (2) non-DOT specification stainless steel\npressure vessels comprise the packaging, is the following description (highlighted in yellow) of\nthe quantity and type of packaging acceptable for shipment by air?\n3. Assuming Interpretation 1 is correct, where should the labels and marks required by Part 172\nsubpart F and E be affixed?\nNote: Due to the design of the gas purification system, the surface of the pressure vessels are not\nvisible as they are covered with heating jackets which cannot be removed for transport. Entegris\nsuggests the marks be placed as shown in the picture in Annex 2.\n4. Assuming Interpretation 2 is correct and all 4 items listed in Question 1 comprise the packaging,\nwhich of the following descriptions of the quantity and type of packaging are acceptable:\nInterpretation 2 − Description for quantity and type of packaging − Option 1\nInterpretation 2 − Description for quantity and type of packaging − Option 2\nPage 4\n\n<<>>\n\nIf both of the above options are incorrect, Entegris would appreciate PHMSA’s guidance on what the\nappropriate description of the quantity and type of packaging is.\n5. Assuming Interpretation 2 is correct, where should the labels and marks required by Part 172\nsubpart F and E be affixed? (Refer to Annex 2 for pictures showing different locations labels and\nmarks can be affixed to)\nEntegris greatly appreciates PHMSA’s attention to this matter and looks forward to a response that further\nclarifies our understanding of the Hazardous Materials Regulations.\nShould PHMSA require additional information to process the interpretation, please contact me at your\nconvenience.\nSincerely,\nJames (Jim) V. McManus\nSr. Principal Engineer\nDangerous Goods Safety Advisor (DGSA)\nEntegris Inc.\nMobile Phone: 203-482-1606\nPage 5\n\n<<>>\n\nThis page includes confidential information\nAnnex 1\nDrawing for Example Gas Purification System\nPage 6\n\n<<>>\n\nThis page includes confidential information\nAnnex 2\nPictures of Gas Purification System\nPage 7","truncated":false,"body_characters":27416}