{"operation":"document","citation":"23-0010","title":"Advanced Printing Solutions — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2023-03-17","effective_on":null,"summary":"23-0010 response to Advanced Printing Solutions concerning 173.150.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-23-0010.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-23-0010.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-23-0010","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/standards-rulemaking/hazmat/interpretations/77436/230010.pdf","body":"<<>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n1200 New Jersey Avenue, SE\nWashington, DC 20590\nMarch 17, 2023\nBill Booth\nAdvanced Printing Solutions\n1201 Edison Drive\nCincinnati, OH 45216\nReference No. 23-0010\nDear Mr. Booth:\nThis letter is in response to your February 1, 2023, letter requesting clarification of the\nHazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to limited quantities\nof “UN1210, Printing ink, flammable or Printing ink related material (including printing ink\nthinning or reducing compound), flammable, 3, PG II.” Specifically, you are shipping “UN1210”\nin bottles—0.475 L each—that will be packaged in boxes containing four of the bottles, and\nthree of these boxes will be consolidated in a larger outer box (for a total of 12 bottles per outer\nbox). You seek confirmation that the printing ink can be shipped in this manner as a limited\nquantity via ground transportation provided the receptacles contain no more than one liter of\n“UN1210” per receptacle.\nSection 173.150 of the HMR offers exceptions for the transport of limited quantities of Class 3\nflammable liquids provided certain conditions are met, including exception from specification\npackaging requirements when packaged in combination packagings, according to § 173.150(b).\nFor Class 3 packing group II material, inner packagings must not exceed 1 L (0.3 gallons) net\ncapacity each, packed in a strong outer packaging, and the gross weight of the package must not\nexceed 30 kg (66 pounds).\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\nFrom: INFOCNTR (PHMSA)\nTo: Hazmat Interps\nSubject: FW: Request confirmation\nDate: Wednesday, February 1, 2023 4:25:54 PM\n23-0010\nPlease see below request for LOI.\nThanks,\nJonathon\nFrom: shipping@kaocollins.com \nSent: Wednesday, February 1, 2023 4:18 PM\nTo: INFOCNTR (PHMSA) \nSubject: Request confirmation\nCAUTION: This email originated from outside of the Department of Transportation (DOT). Do\nnot click on links or open attachments unless you recognize the sender and know the content\nis safe.\nHello to whom it may concern.\nWe have talked to a couple of different people from the DOT Hotline, but we do need some\nclarification in writing please.\nREF: 49 CFR 173.150 (b) 2\nLimited Quantity\nWe are trying to ship 12 bottles (receptacles) of .475L printing ink (UN1210 Flammable Ink). 4 of\nthese bottles will fit into 1 box and then ship 2 others as well with it (total of 12 bottles of .475L\nFlammable printing ink each bottle) for a total of 3 inner boxes into 1 outer box that will hold all 12\nbottles. According to how we’ve been told now, this CAN be shipped as Limited Quantity via the 48\nstates in the US, as long as the box containing all these receptacles contain no more than 1 Liter of\nhazardous material? We want to make sure that this is correct? This can be shipped as Limited\nQuantity Ground, PG II.\nWe do await your reply as soon as you can.\nThank you.\nBill Booth\nShipping and Receiving\nKao Collins, Inc.\n\n<<>>\n\nAdvanced Printing Solutions\n1201 Edison Drive\nCincinnati, Ohio 45216 USA\nOffice: 513-948-9000\nFax: 513-948-8900\nshipping@kaocollins.com\nConfidentiality Notice: This e-mail message, including all accompanying documents, may contain\ninformation which is confidential, privileged or otherwise protected from disclosure under law. The\ninformation is intended only for the person(s) to whom it is addressed. If the recipient of this e-mail\nis not the designated recipient or the employee or agent responsible for delivering this e-mail to the\ndesignated recipient, you are hereby notified that any use, review, disclosure, copying, distribution,\nalteration or manipulation of this e-mail or its contents is strictly prohibited. If you have received this\ne-mail in error, please notify the sender and delete the e-mail from your computer system\nimmediately.","truncated":false,"body_characters":4103}