Advanced Printing Solutions — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Avenue, SE Washington, DC 20590 March 17, 2023 Bill Booth Advanced Printing Solutions 1201 Edison Drive Cincinnati, OH 45216 Reference No. 23-0010 Dear Mr. Booth: This letter is in response to your February 1, 2023, letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to limited quantities of “UN1210, Printing ink, flammable or Printing ink related material (including printing ink thinning or reducing compound), flammable, 3, PG II.” Specifically, you are shipping “UN1210” in bottles—0.475 L each—that will be packaged in boxes containing four of the bottles, and three of these boxes will be consolidated in a larger outer box (for a total of 12 bottles per outer box). You seek confirmation that the printing ink can be shipped in this manner as a limited quantity via ground transportation provided the receptacles contain no more than one liter of “UN1210” per receptacle. Section 173.150 of the HMR offers exceptions for the transport of limited quantities of Class 3 flammable liquids provided certain conditions are met, including exception from specification packaging requirements when packaged in combination packagings, according to § 173.150(b). For Class 3 packing group II material, inner packagings must not exceed 1 L (0.3 gallons) net capacity each, packed in a strong outer packaging, and the gross weight of the package must not exceed 30 kg (66 pounds). 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 2Baker From: INFOCNTR (PHMSA) To: Hazmat Interps Subject: FW: Request confirmation Date: Wednesday, February 1, 2023 4:25:54 PM 23-0010 Please see below request for LOI. Thanks, Jonathon From: shipping@kaocollins.com <shipping@kaocollins.com> Sent: Wednesday, February 1, 2023 4:18 PM To: INFOCNTR (PHMSA) <INFOCNTR.INFOCNTR@dot.gov> Subject: Request confirmation 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. Hello to whom it may concern. We have talked to a couple of different people from the DOT Hotline, but we do need some clarification in writing please. REF: 49 CFR 173.150 (b) 2 Limited Quantity We are trying to ship 12 bottles (receptacles) of .475L printing ink (UN1210 Flammable Ink). 4 of these bottles will fit into 1 box and then ship 2 others as well with it (total of 12 bottles of .475L Flammable printing ink each bottle) for a total of 3 inner boxes into 1 outer box that will hold all 12 bottles. According to how we’ve been told now, this CAN be shipped as Limited Quantity via the 48 states in the US, as long as the box containing all these receptacles contain no more than 1 Liter of hazardous material? We want to make sure that this is correct? This can be shipped as Limited Quantity Ground, PG II. We do await your reply as soon as you can. Thank you. Bill Booth Shipping and Receiving Kao Collins, Inc.#

Page 3Advanced Printing Solutions 1201 Edison Drive Cincinnati, Ohio 45216 USA Office: 513-948-9000 Fax: 513-948-8900 shipping@kaocollins.com Confidentiality Notice: This e-mail message, including all accompanying documents, may contain information which is confidential, privileged or otherwise protected from disclosure under law. The information is intended only for the person(s) to whom it is addressed. If the recipient of this e-mail is not the designated recipient or the employee or agent responsible for delivering this e-mail to the designated recipient, you are hereby notified that any use, review, disclosure, copying, distribution, alteration or manipulation of this e-mail or its contents is strictly prohibited. If you have received this e-mail in error, please notify the sender and delete the e-mail from your computer system immediately.#