Goshen Corporate Park West — Hazardous Materials Safety Interpretation

Page 1U.S.Department of Transportation 400 Seventh Street, SW Special Programs Research and Washington, D C 20590 Administration JUN - 4 1998 MI. David B. Caria Director, VWR Scientific Products Regulatory Affairs Goshen Corporate Park West Ref. No. 98-0020 1310 Goshen Parkway west Chester, PA 19380 Dear Mr. Caria: This is in response to your letter of April 8, 1998, regarding units of measurement required in a shipping paper entry in accordance with 49 CFR S 172.202 (a) (5) • Specifically, you ask appropriate unit of measurement. whether the gross weight of the package in pounds would be an The answer is yes. empty packages, cylinders, and bulk packages, that the total Section 172.202 (a) (5) requires, except for quantity including the unit of measurement of the hazardous materials covered by the description be included in the shipping papers. weight, capacițy, or as otherwise appropriate. Total quantity may be entered as net weight, gross Pounds may be i gross weight. used as an adequate unit of measurement to express either net or I hope this satisfies your request. Sincerely 1 Billings Standards Development Office of Hazardous Materials Standards 112.202#

Page 2contractor ViA Scientific File: 172.202(a)(5) Products Goshen Corporate Park West West Chester, PA 19380 1310 Goshen Parkway Main (610) 431-1700 April 8, 1998 DOT/RSPA/OHMS Mr. Edward Mazzullo, DHM-10 400 7th Street, S.W. Washington, DC 20590 RE: Request For An Opinion Dear Mr. Mazzullo: VWR Scientific Products is a distributor of laboratory supplies. As part of this, we ship many small packages of liquid hazardous materials. It is presently our practice to show the total quantity contained in each combination package as gross weight of the package in pounds. It is our belief that this is an appropriate unit of measure as required by 49 CFR 172.202 (a)(5). I respectfully request your opinion on whether or not gross weight in pounds is an appropriate unit of measure for relatively small quantities of liquid hazardous chemicals shipped in combination packages. Four liters of acetone in a glass bottle, packaged in a 4GV package would be a typical shipment. If you have questions or need clarification, I can be reached at 610-429-2814. Sincerely, David Blain David B. Caria Director Regulatory Affairs DClamb#