Toyota Motor Sales, U.S.A.,Inc. — Hazardous Materials Safety Interpretation

Page 1. of Transportation U.S. Department Washington, D.C. 400 Seventh Street, S.W. 20590 Special Programs Research and Administration SEP 2 5 1998 Anthony P. Willson Toyota Motor Sales, P.O. Box 2991 U.S.A., Inc. Ref. No. 98-0277 Torrance, CA • 90509-2991 Dear Mr. Wilison: This is in response to your letter dated September 9, 1998, concerning the gross weight marking on a specification packaging under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171- 180).. Specifically, you ask if packages may contain less weight the gross mass which is marked on the packaging. Section 178.503 specifies the markings which must appear on a UN standard packaging. For packagings intended to contain solids or inner packagings, the designation of the mass of the packaging must be the maximum gross mass in kilograms for which that packaging has been tested (178.503 (a) (4) (ii)). The gross weight of the package must not exceed the box. Therefore, packagings may contain materials in amounts the maximum gross mass printed on less than specified in the printed markings. I hope the satisfies your request. Sincerely, Transportation Regulations Specialist Office of Hazardous Materials • Standards • a gain#

Page 2BAH $ 178.503 •TOYOTA 9001 South Western Avenu 'oyota Motor Sales, U.S.A., In Torrance, CA 90509-2991 P.O. Box 2991 310) 618-4000 310) 618-7800 Fa September 9, 1998 GO Mr. Edward Mazzullo Director Office of Hazardous Material Standards 700 7* Street S. W. Washington, DC 20590 Dear Mr. Mazzullo: Toyota Motor Sales, USA receives parts from Japan that are Seat Belt Pre-tensioners and Air Bag Modules, Class 9, UN3268, packing group Ill. These parts have a gross weight of 2.27 kg or 2.50 kg. The UN specification printed on the box is 3.0 kg. Currently we are adjusting the gross weight on the boxes received from our Japan suppliers to the exact gross weight. We received two different answers to our verbal inquiries regarding this matter. One answer, from our outside consultant, Steven Hunt of ShipMate, is that the gross weight must be exact. The answer from Mike Johnson at the DOT was that the gross weight cannot exceed that which is printed on the box. Since we ship these parts to facilities within the United States we would like to know which is correct for transport within the United States. I would appreciate a phone call on this issue. Please call me at 310-787-5701. If l am not in please leave a voice mail message. A written response is also requested. Sincerely, Anthony P. Willson Sr. Logistics Administrator Mail Stop G-401 /#