Wright Corporation — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department 400 Seventh Street, S.W. Research and Washington, D.C. 20590 12. Administration Special Programs AUG ..7 1998 Mr. Rick Wells Traffic Manager Ref. No. 98-0210 Wright Corporation P.O. Box 402 Riegelwood, NC 28456 Dear Mr. Wells: This is in response to your letter of July 23, 1998, regarding securement requirements under the Hazardous Materials Regulations (HMR 49 CER Parts 171-180). Specifically you describe a scenario '! consisting of either 2000 pound supersacks or 50 pound bags unsecured pallets. (layered with glue between each layer) loaded onto small You state that each unit is loaded with the bags pressed against each other and the trailer walls and you use load locks on the last two units. As provided by § 177.834 (g), packages of hazardous materials must be so braced as to prevent motion within the transport vehicle. The scenario you provided seems to meet this requirement; be a violation of the HMR. however, movement of packages within the transport vehicle would Sincerely, Office of Hazardous Materials Standards :#

Page 25UL-23-1998 16:27 WRIGHT CORP 19106559671 P.02 A.. WRIGHT CORPORATION Lavalle July 23, 1998 MIs. Diane LaValle U.S. Departrent of Transportation 400 Seventh Street, S.W. Room # 8102 DHM-10 Washington, D.C. 20590 Dear Mrs. LaValle: Per our telephone conversation. I am writing this letter to clarify our request for a ruling on CRF 177.834G, and how it relates to the packaging and shipment of our product, Hexamethylenetetromine. This product is shipped in either 2,000 LB FIBCs or in 50 LB bags (7 bags per layer, 6 layers high with glue between each layer). These bags are placed on a slightly undersized and unsecured pallets. These units, when loaded, are placed with the bags pressed against the adjacent units bags. Therefore, the bag or bags are blocking thernselves against each other and the trailer walls. This along with load locks on the last two units should prevent motion when in transit. With the use of performance oriented packaging and our blocking method, we feel that each truck load of material wall arrive at it's destination safely as has been our history for many years now. Sincerely, Rich Welle Rick Wells Traffc Mgr. Wright Corp P.O. BOX 402. RIEGELWOOD, N.C. 28456 TELEPHONE 919-655-2263 • FAX 919-655-9671 TOTAL P.02#