Coty Riverside Distribution Center — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Avenue, SE Washington, DC 20590 January 19, 2023 Ms. Janice Hayes Logistics Customer Service Manager Coty Riverside Distribution Center 4608 Appliance Drive Belcamp, MD 21017 Reference No. 22-0072 Dear Ms. Hayes: This letter is in response to your June 28, 2022, letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to labeling shipments of limited quantities. In your letter, you provided pictures of a limited quantity package that has the limited quantity marking reproduced on multiple sides of the package. You note that in some instances, one of the limited quantity markings may be covered by a shipping label; however, the remaining limited quantity markings remain visible on the package. You ask whether this situation is permissible, i.e., to possibly cover up one of the limited quantity markings on the package, provided at least one other limited quantity marking is visible on the package. Based on the description and photographs provided in your letter, the answer is yes. Section 172.315(a)(2) states that the limited quantity square-on-point marking “must be durable, legible, and of a size relative to the packaging, readily visible, and must be applied on at least one side or one end of the outer packaging.” The HMR do not prohibit the placing of multiple limited quantity markings on a package, such as depicted in your photographs, provided the applicable requirements in § 172.315 are met. However, it is the opinion of this Office that a partially- obscured limited quantity marking—as pictured in your incoming letter—should be covered to avoid frustration of your shipment during transportation. I hope this information is helpful. Please contact us if we can be of further assistance. Sincerely, T. Glenn Foster Chief, Regulatory Review and Reinvention Branch Standards and Rulemaking Division#

Page 2From: INFOCNTR (PHMSA) To: Dodd, Alice (PHMSA) Cc: Hazmat Interps Subject: FW: COTY Correspondence Date: Friday, July 22, 2022 1:51:54 PM Attachments: EO - Approv(COTY) 12Jul22.pdf image002.png image004.png Hi Alice, Please see the attached LOI request. Let me know if you need anything from us. Regards, -Breanna From: Nicks, Michael (PHMSA) <michael.nicks@dot.gov> Sent: Tuesday, July 12, 2022 11:06 AM To: INFOCNTR (PHMSA) <INFOCNTR.INFOCNTR@dot.gov> Subject: FW: COTY Correspondence FYA. Michael Nicks Transportation Specialist, Office of Hazardous Materials Safety US Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Ave., Washington D.C. 20590 Office: 202-366-5610 PHMSA Home | LinkedIn | Twitter | HAZMAT | OPS From: Approvals (PHMSA) <Approvals@dot.gov> Sent: Tuesday, July 12, 2022 11:02 AM To: Nicks, Michael (PHMSA) <michael.nicks@dot.gov> Subject: FW: COTY Correspondence Duane M. Cassidy Chief, Pressure Vessels Branch (PHH-25)#

Page 3Sciences and Engineering Division Office of Hazardous Materials Safety US Department of Transportation Pipeline and Hazardous Materials Safety Administration E21-301, 1200 New Jersey Ave SE, Washington, DC 20590 Office: 202.366.5794 ◊ Mobile: 202.596.0583 PHMSA Home | LinkedIn | Twitter | HAZMAT | OPS From: Lisak, Frank (PHMSA) <frank.lisak@dot.gov> Sent: Tuesday, July 12, 2022 10:32 AM To: Approvals (PHMSA) <Approvals@dot.gov> Subject: COTY Correspondence Good Morning, Gentlemen: The attachment is for your review. Frank#