H.B. Fuller Automotive Company — Hazardous Materials Safety Interpretation

Page 1-1 U.S.Department of Transportation 400 Seventh Street, S.W Washington, DC. 20590 Special Programs Research and Administration AUG 1 4 1998 • Mr. Eugene J. Secor EHS/Transportation Specialist Ref. No. 98-0224 H.B. Fuller Automotive Company 31601 Research Park Drive Madison Heights, Michigan 48071 Dear Mr. Secor: This responds to your letter concerning shipping paper requirements of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask whether information concerning a shipment may be included on a shipping paper so that it can serve the dual purposes of a bill of lading and a packing The HMR do not specify a particular format for shipping papers. .- Rather, Subpart C of Part 172 sets forth the information that must be included on shipping papers and the order in which that information must appear. you enclosed with your The "mock-up" shipping document that provided the requirements of Subpart C are met. letter may be used as a shipping paper In this regard, we note that your "mock-up" does not include hazardous materials shipping descriptions. For shipments of hazardous materials, the required shipping description means the basic description required by § 172.202, and additional description information required by § 172.203. The basic description, consisting of the proper shipping name for the material as identified in § 172.101 of the Hazardous Material Table, the hazard class, the identification number and the packing group, if any, must be shown in sequence with no additional information interspersed. Additional information, as that required by § 172.203; or other additional information concerning the hazardous material must be placed after the basic description on a shipping paper, except that technical name or chemical group name for a generic description may follow the proper shipping name. allowed to be placed before the basic description is quantity The only information shipped, and the type of packaging and destination marks (see § 172.201 (a) (2) (iii), § 172.201 (a) (4) and § 172.202 (c)). Thus, you may include packing slip data applicable to a hazardous materials shipment on a shipping paper, but that information must 172.202#

Page 2• 2 be shown after the required shipping description. As you develop your shipping documents, you should also be aware shipping paper (see OI requirements for including a shipper's certification on the nazardous materials must be accompanied by emergency response § 172.204). In addition, most shipments of information, including an emergency response telephone number (see Subpart G of Part 172). I hope this information is helpful. If you have further questions, please do not hesitate to contact this office. Sincerely, Thoman A. Allan Thomas G. Allan Senior Transportation Regulations Specialist vIlice oI Hazardous Materials Standards • •........... * ...........#

Page 3H.B. Fuller Automotive Company Gorsky 31601 Research Park Drive §172.202 (810) 585-2200 • (800) 633-7789 Madison Heights, Michigan 48071 AUGUST 5, 1998 FAX (810) 585-3699 US DEPARTMENT OF TRANSPORTATION RESEARCH AND SPECIAL PROGRAMS ADMINISTRATION STANDARDS DEVELOPMENT, DHM-11 400 SEVENTH STREET, S.W. WASHINGTON, DC 20590 ATTENTION: MR DELMER F. BILLINGS CHIEF, REGULATIONS DEVELOPMENT Dear Mr. Billings: In an effort to streamline and consolidate our paper flow, the question has arisen as to what exactly can be of papers generally accompany a shipment regardless of whether the material is hazardous or not. These put on a shipping paper (Bill of Lading). The impetus behind this effort has to with the fact that two sets papers are the Bill of Lading which goes with the truck driver and a packing list which is usually attached to the container for a specific customer. legally as a shipping paper and as a packing list while also being mindful of 172.201(4). Would inclusion The crux of the question is whether a shipping paper can serve theses duel purposes; namely, function of normal packing slip data on the BL after all shipping entries have been entered be a violation? I have attached a "mock up" of what we propose to do. Assuming our proposal is in compliance, could you comment on a better lay out for the mock-up? Rest assured that we are not doing this currently; this is simply a query at this point. If there are any questions, feel free to contact me at 810-498-1317. Sincerely, HB FULLER COMPANY Esperar EUGENE J SECOR EHS/TRANSPORTATION SPECIALIST cc: Sarah Obser -- Willow Lake B Brian Lim - Lexington Ave Cathy Boussie - Madison Heights#

Page 4→ so in |BILL OF LADING NO. 44831 DATE PACE 6/1/98 1 of 2 02000298 I SHP FROM SHIP TO DEST GENERAL MOTORS OF CANADA PLANT *2 DOCK QQQ GENERAL MOTORS OSHAWA CANADA OSHAWA, ONTARIO L1H 8P7 PREMHIM TRANSPORTATION AUTHORIZATION FOB Terms: FOB Shipping Point/Collect MODE METHOD SCAC REGULATORY INFORMATION ONLY - RECEIVING INFORMATION BELOW NUMBER KIND PACKAGING H.M. SPECIFIC MARKS AND EXCEPTIONS DESCRIPTION OF ARTICLES Subject to Correction WEIGHT - 9 BX NOT A REGULATED MATERIAL, LIQUID OR PASTE, IN BARRELS, BOXES OR PACKAGE COMPOUNDS VEHICLE BODY SEALER OR SOUND DEADENER, 153 1235, ITEM # 50315, CLASS 55 FS703M30 HOT MELT STICK 1004269007 3 MD - COMPOUNDS VEHICLE BODY SEALER OR SOUND DEADENER, NOT A REGULATED MATERIAL, 15150 1235, ITEM # 50315, CLASS 55 LIQUID OR PASTE, IN BARRELS, BOXES OR PACKAGE WC2231 MP UNDERBODY COATING 1100010202 GROSS WEIGHT NET WEIGHT 15903 RECEIVING INFORMATION BELOW CUST. RELEASE CUST. PURCHASE ORDER CUST. PART NO./ RESOURCE DESCRIPTION CUST. SEAL NO RESOURCE NO. EFTEC ORDER NO. CONTAINER UOM QUANTITY CUSTOMER UOM LOT NUMBER • 81HM6 OSR842443 2027505 52799 FS703M30 HOT MELT STICK 1004269007 BX" 450 1480556431 1480556444 **CONTINUED**#

Page 5o i. I BAL OF 408310. DATE 6/1/98 PAGE 2 of 2 02000298 I SHIP FROM SHIP TO DEST GENERAL MOTORS OSHAWA GENERAL MOTORS OF CANADA SHAWA, ONTARIO LTH 8P LANT #2 DOCK QQC PREMIUM TRANSPORTATION AUTHORIZATON FOB Terms: FOB Shipping Point/Collect MODE METHOD SCAC RECEIVING INFORMATION BELOW CUST. PURCHASE ORDER/ CUST. PART NO. / CUST. RELEASE RESOURCE DESCRIPTION CUST. SEAL NO. RESOURCE NO. EFTEC ORDER NO. CONTAINER UOM QUANTITY CUSTOMER ƯOM LOT NUMBER OSR842442 DHB01217 SEAL-0270 9984175 52800 WC2231MP UNDERBODY COATING 1100010202 MD 15000 LB 10000 3000 2000 1480554000 1480553996 1480553213 *HASN REQUIRED: SHIP TIME Messages: Ship on Tuesday - Receiving hours at GM are (8:30 - 12:00 noon) only. Bar code must have viscosity. Messages: VIS & BKFLD REQUIRED ON LABEL - CERTS REQ'D. 90 DAY EXPIRATION GREEN DRUM W/LINER & COVER SHEET#

Page 6-CARRIER STRAIGHT BILL OF LADING - SHORT FORM ORIGINAL. - NOT NEGOTIABLE BILL OF LADING NO. *ETEC North America, L.L.C. AT RECEIVED sulet the hasicans and and id ant to the dare teste the il of LadiSHMENT ID COLLECTED ON DELIVERY EQUIPMENT ID AMT $. MODE METHOD SCAG FEE $. TOTAL $. NUMBER KIND PACKAGING H.M. SPECIFIC MARKS AND EXCEPTIONS DESCRIPTION OF ARTICLES Subject to Correction WEIGHT condition of applicable bill Subject to Section 7 of of lading. If this shipment is signee without recourse on to delivered to the con or shall sign the following the consignor, the consign- statement. BL format ve delivery of this shipment The carrier shall not make without payment of freight and all other lawful charges. Aurally ase!! EFTEC North America, L.L.C. (Signature of Consignor) "To be Prepaid." aid, write or stamp her charges are to bo pr Received $ the charges on the property to apply in prepayment of described hereon. Agent or Cashier acknowledges only the (The signalure here amount prepaid.) Charges Advanced FOR CHEMICAL EMERGENCY *If the shipment moves between two ports by a carner by water, the law requires that the bill of lading CALL NOTE - Where the ratc is dependent on valuc, shippers are required to state specifically in wnting the shall state whether it is carrier's or shipper's weisht. STATED SHIPPER CHEMTREC agreed or declared value of the property. BE NOT EXCEEDING 165 CENTS PER POUND FOR EACH ISTRIBUTION PACKAGE 1-800-424-9300 DAY OR NIGHT IN PROPER CONDITION FOR TRANSPORTATION, ACCORDING TO THE APPLICABLE REGULATIONS OF THE DEPARTMENT OF TRANSPORTATION. THIS IS TO CERTIFY THAT THE ABOVE NAMED MATERIALS ARE PROPERLY CLASSIFIED, DESCRIBED, PACKAGED, MARKED AND LABELED AND ARE Dox mares ceriseat there, and alone reco openis i to consider reight Classification. rate more oms enamp, not a part of bill of lading approved by the Permanent post oflice address of shipper EFTEC North America, L.L.C (Shipper) Per ORIGINAL - NOT NEGOTIABLE Agent, Per.#

Page 7EMERGENCY RESPONSE GUIDES (ERG) POTENTIAL HAZARDS ERG 11 FIRE OR EXPLOSION - Flammable/combüstible material; may be ignited by heat, sparks or flames. May inte other combustible matertals (wood; paper, öll, etc.) Container may explode in heat of fire. Reaction with fuels may be violent. Runoff to sewer may create fire or explosion hazard. HEALTH HAZARDS - Maybe fatal if inhaled, swallowed or absorbed through ski Contact may cause burns io skim and ayes, fire may produca ritaling or poisonous gases. Rumit tom, tre control or diligion water may cause pollution". Keep unnecessary people away; isolate hazard area and deny entry. Stay upwind; keep out of low areas. Posive pressure self-contained breathing apparatus (SCA) and strictural firefighters protective clothing will provide limited protection. EMERGENCY ACTION CALL Emergency Response Telephone Number on Shipping Papers first. If Shipping Paper not avallable or no answer, CALL CHEMTREG AT 1-800-424-9300. If water pollution occurs, notify the appropriate authorities. Move container from fire area If you can do it without risk. Apply cooling water to sides of containers that are exposed to flames until well after. fire is out. Stay away from ends of tanks. For massive fire in cargo area, use Unmanned hose holde EIRE - Small Fires: Dry chemical, CO2, water spray or regular foam. Large Fires: Water spray, fog br regular foam SPILL OR LEAK - Shut off Ignition sources; no flares, smoking or flames in hazard area. Keep combustibles. (wood. paper, oil, etc.) away from spilled material. Do not touch or walk through spilled material. Small Spills: Take up with sand or or monitor nozzles; if this is impossible, withdraw from area and let fire burn. FIRST AID - Move-victim to fresh air and call emergency medical care; if not breathing, give artificial respiration; if breathing is difficult, give oxygen. In case of contact with material, immediately flush skin or eyes with running water for at least. other noncombustible absorbent material and place into containers for later disposal: Large Spills: Dike far ahead of liquid spill for later disposal.. 15 minutes: Remove and isolate contaminated clothing and shoes at the site. Keep victim quiet and maintain normal body temperature. POTENTIAL HAZARDS ERG 26: sewers. Runoff to sewer may create fire or explosion hazard. FIRE OR EXPLOSION - Flammable/combustible material; may be ignited by heat, sparks or flames. Vapors may travel to a source of Ignition and flash back. Container may explode in heat of fire. Vapor explosion hazard indoors, outdoors or in HEALTH HAZARDS. - May be poisonous if inhaled, swallowed or absorbed through skin. Vapors may cause dizziness or suffocation. Contact may irritate or burn skin and eyes. Fire may produce irritating or polsonous gases. Runoff from fire con- trol or dilution water may oive off poisonous gases and cause water pollution. EMERGENCY ACTION Isolate for 1/2 mile in all directions I tank, rall car or tank truck is involved in fire. CALL Emergency Response Telephone Number on Shipping Papars first. If Shipping Paper not avallable or ne answer, CALL CHEMTREC AT 1-800-424 Keep unnecessary people away; isolate hazard area and deny entry. Stay upwind; keep out of low areas. Positive pressure self-contained breathing apparatus (SCBA) and structural firefighters' protective clothing will provide limited protection 9300, If water pollution occurs, notify the appropriate authorities. loye container trom fire area if you can do it without risk. Apply cooling water to sides of containers that are exposed to flames until well after. fire is out. Stay away from ends of tanks. For massive fire in targo area, use unmänned hose hold RE-Small Fires: Dry chemical, CO2, water spray or alcohol-resistant foam. Do not use dry chemical extinguishers to control fires involving nitromethane or nipoethene. Large Fires: Water spray, fog or alcohol-resistant foar witor monitor nozzles: i-this is Impossible, withdraw from area and let fire burn: Withdraw immediately in case of rising sound from venting safety dey ce or any discoloration of tank due.to tin 'SPİLL OR LEAK - Shut off ignition sources, no flares, smioking or flames ih hazard area: Stop leak if you cari do it withöut risk. Water spray may redice vapor; but it may not prevent ignition coset spages. Bmalf Splus: Take up with sand i FIRST AID - Move victim to fresh air and call emergency medical care; if not breathing, give artificial respiration; if breathing is difficult, give oxygen. In case of contaçt with material, immediately flush skin or eyes with running water for at least other noncombustible absorbent material and place into containers for later disposal. Large Spills: Dike far ahead of liquid spill for later disposal. 15 minutes. Wash skin with soap and water. Remove and isolate contaminated clothing and shoes at the site. POTENTIAL HAZARDS ERG 27: FIRE OR EXPLOSION = Flammable/combustible material: may be ignited by heat, sparks or flames. Vapors may travel to a source of ignition and flash-back. Container may explode in heat of fire. Vapor explosion hazard indoors, outdoors or in HEALTH HAZARDS - May be poisonous it inhaled, swallowed or absorbed through skin. Vapors may cause dizziness or suffocallon. Contact may Irritate or burn skin and eyes. Fire may produce irritating or poisonous gases. Runoff from tire con- sewers. Runoft to sawer-may. create fire or explosion hazard. Material may be transported hot. trol or dilution water may cause pollution. Keep unnecessary people away; isolate hazard area and deny entry. Stay upwind; keep out of low areas. Positive pressure self-contaned breathing apparatus (SCBA) and structural firefighters' protective clothing will provide limited protection. EMERGENCY ÄCTION Isolate for 1/2 mile in all directions if tank, rail car or tank truck is Involved'in fire, CALL Emergency Response Telephone Number on Shipping Papers first. If Shipping Paper not available or no antwer, CALL CHEMTREC AT 1-800-424- Move container from fire area it you can do it without risk. Apply cooling water to sides of contalners that are exposed to flames until well after fire is out. Stay away from ends of tanks. For massive fire in cargo area, use unmanned hose holder FIRE - Small Fires: Dry chemical, CO2, water spray or regular foam. Large Fires: Water spray, fog;or regular foam. 9300. If water pollution occurs, notify the appropriate authoritles. SPILL OR LEAK - Shut. off ignition sources: no flares, smoking or flames in hazard area. Stop leak if you can do it without risk. Water spray may reduce vapor, but it may not prevent ignition in closed spaces. Small Spills: Take up with sand or or monitor nozzles: if this is impossible, withdraw from area and lét fire burn. Withdraw immediately in case of rising sound from venting safety device or any discoloration of tank due to fire. other noncombustible absorbent material and place into containers for later disposal. Large Spille; Dike far ahead of liquid spill for later disposal. utes. Wash skin with soap and water. Remove and isolate contaminated clothing and shoes at the site. FIRST AID - Move victim to fresh air and call emergency medical care; if not breathing, give artificial respiration; if breathing is difficult, giø oxygen. i case of contact with material, imidiately flush eyes with running water for at least 15 min- POTENTIAL HAZARDS ERG 31 FIRE OR EXPLOSION - Some of these materials may burn, but none of them Ignites readily: Material may be transported hot. HEALTH HAZARDS - Contact may cause burns to skin and eyes. Inhalation of asbestos dust may have a damaging effect on the lungs. Fire may, produce irritating or poisonous gases. Runoff from fire control or dilution water may cause pollutian: Number on Shipping Papers first. If Shipping Paper not available or no answer, CALL CHEMTREC AT 1-860-424-9300. If water pollution occurs, notily the appropriate authoritles. red unnecessary pale away: isolate hazard area and deny entry. Postive prassure self-contained breathing apparatus (SCA) and strüctural trefighters' protective clothing will provide limited protection: CALL Emergeney Responso Telephone EIRE - Small Fires: Dry. chemical, C02, water spray or regular foam. Large Fires: Water spray, fog or regular foam. SPİLL OR LEAK - Stop leak if vou can do it without risk. Avoid inhalation of asbestos dust. Small; Dry Spillis: With clean shovel place matertal into clean, dry container and cover loosely; move containers from spill area. Large Spills: Dike far Mave container from fire area if you can do it without risk. Do not scatter spilled material with high-pressure water streams. Dike fire control, water for later disposal. aHAST AD - in case of contact with material, immediately flush eyes with running water for at least 15 minutes. Wash skin with soap ah water. Ramove and isolate contaminated clothing and shoes at the sile. ahead of Jiquid spill for/ater disposal. Cover powder spill with plastic sheet or tarp to minimize spreading. POTENTIAL HAZARDS ERG 37 HEALTH HAZARDS - It inhaled; may be harmful. Gontact may cause burns to skin and eyes: Fire may produce ritating or poisonous gases. Runoff from fire control or dilution water may cause pollution. FIRE OR EXPLOSION - Flammahle/combustible material. May ignite itself if exposed to air. May reighite after fire is extinguished. May burn rapidly with flare-burning effect. Runoff to sewer may create fire or explosion hazard. Keep unnecessary people away; isolate hazard area and deny entry. Stay upwind; keep out of low areas. Positive pressure self-contained breathing apparatus (SCBA) and structural firefighters" protective clothing will provide limited protection. EMERGENCY ACTION FIRE - Some of these materials may react violently with water. Hydrosultite Fires: Use flooding quantities of water for any size fire: Small Fires: Dry chemical, soda ash, fime or sand Large Fires: Flood fire area with water trom a distance CALL Emergency Response Telephone Number on Shipping Papers Irat. It Shipping Paper not akallable or no anawer, CALL CHEMTREC AT 1-800-424-9300. IS water poilution occurs, notify and appropriate authorities. aréa, use unmanned hose holder, or monitor nozzles; if this is impossible, withdraw from area and let fire burn. Do not get water inside container. Move container from fire area If you can do it without risk. Apply Cooling water to sides of containers that are exposed to flames until well after fire is out. Stay away from ends of tanks. For massive tire in cargo SPILL OR.LEAK - Do not touch or walk through spilled material; stop leak if you can do it without risk. Do not get water inside container. Smail Spills: Flush areas with flooding amounts of water. Large Spills: Dike liquid spill for later disposal FIAST AID - Move victim to fresh air and call emergency medical care. In case of contact with material, immediately flush skin or eyes With running water for at least 15 minutes. Remove and isolate contaminated clothing and shoes at the site: POTENTIAL HAZARDS ERG 60 SHEALTH HAZARDS Contact causes burns to skin and eyes. I inhaled may be harmful: Fire may produce irritating or poisonous gases. Runoff from fire control or dilution water may cause pollution IKMERGENCY ACTION Keep unnecessary people away; isolete hazard area and deny entry. Stay upwind: keep.out of low areas. Positive pressure self-contained breathing apparatus (SCBA) and structural-firefighters' protective clothing will provide limited proteglion. CALL Emergency Response Telephone Numher on 8hipping Papers (Irst. It Shipping Paper not avalable or ne answer. CALL CHEMTREG-AT 1-800-424-9300, It water pollution occurs, notify the appropriate authorities. FiRE - Some of these materials may react violently with water. Small Fites: Dry chemical, CO2, water spray or regular foam. Large Fires: Water spray, fog or regular foam 2: 3241 SPILL OR LEAK * Do not touch or walk througlt spilled material: stop leak if you can do it without risk: 8mall Spills: Take-up with sand or other noncombustible absorbent material and place into containers for later disposal: Small Dry Spills: Move container from fire area if you can do it without risk. Apply cooling water to sides of containers that are exposed to flames until well after fire is out. Stay away from ends of tanks. FIRST AID Move victim to resh all, cal emergency medical care. Ih case of contact with material, irmediately flush skin or eyes with ginning water for at least 15 minutes. Remove and isolate contaminated clothing and shoes at the site. Keep With clean shovel place material into clean, dry container and cover loosely, move containers from spill areas. Large Spllis: Dike far ahead of liquid spill for later disposal. victim gulet and maintain normal body temperature.#