Hazmateam, Inc. — Hazardous Materials Safety Interpretation

Page 1U.S.Department of Transportation Washington, D.C.S590 Washington, D.C. APR 2- 1998 Mr. Leo Traverse Hazmateam, Inc. 12 Kimball Hill Road Hudson, NH 03051-3915 Dear Mr. Traverse: This is in response to your letter and telephone conversation with a member of my staff concerning the marking and labeling requirements for palletized non-bulk packages containing four different classes of hazardous materials that are overpacked with clear shrink wrap. I apologize for the delay in responding and hope it has not caused any inconvenience. Your questions are paraphrased and answered as follows: QI. If markings and labels on the packages that represent all four hazard classes are visible when viewed from each different side, am I required to mark and label the outside of the shrink wrap? A1. If each package is properly marked and labeled and if markings and labels representative of each hazardous material contained within the overpack are visible, the answer is no. The markings and labels are not required to be repeated on the overpack. See 49 CFR 173.25. Q2. If markings and labels on the packages that represent all four hazard classes are NOT visible when viewed from each different side, am I required to mark and label the outside of the shrink wrap? : A2. Yes. When packages are stacked and banded on a pallet, the packages should be positioned, when possible, so that the markings and labels are visible on the outside of the stack. If markings and labels representative of each hazardous material in the overpack are not visible from any side, the overpack must be marked and labeled for that hazardous material. As an example, if four packages of Acetone, 3, UN1090, are loaded next to other packages so that their markings and labels are not visible, the proper shipping name, identification number, and a Class 3 label for the Acetone must be displayed on one side or end of the overpack, except that duplicate labeling must be -#

Page 2- displayed on at least two sides or two ends (other than the bottom) of each overpack having a volume of 1.8 cubic meters (64 cubic feet) or more. See § 172.406(e). I hope this information is helpful. If we can assist you further, please contact us. Sincerely, Natte z. Artedel Hattie L. Mitchell, Chief Regulatory Review and Reinvention Office of Hazardous Materials Standards#

Page 37... .. : - of Transportation U.S.Department 400 Sevenin Street SW Research and Wasningion OC 30530 Administration Special Programs JUL 20 1994 - Ms. Beth Hagstad Environmental Affairs Specialist Carter-Wallace, Inc. P.O. Box 1001 Cranbury, NJ 08512-0181 Dear Ms. Hagstad: This 'is in hazardous materials which are now being disposed of as hazardous wastes. You response to your letter concerning labeling requirements for place state that packages will be palletized and shrinkwrapped and ask 1f you may cartons. I apologize for the delay in responding and hope it has not caused ' the required DOT labeling on the shrinkwrap and not on the individual any inconvenience. The answer is no. The' labeling requirements found in 49 CFR 172.400 require each non-bulk package to be labeled with the label specified for the material bear markings and labels representative of each hazardous material contained in the § 172.101 Iable. In addition, each overpack (e.g., shrinkwrap) must § 173.25). therein, unless the markings and labels on the packages are visible (see I hope this information is helpful. Sincerely, Wahme Als no. • Delmer F. Billings Chief, Office of Hazardous Materials Standards Regulations Development 172.400 123.25#

Page 4: ! of Transportation US Department Research and Administration Special Programs NOV I 1995 : 9 Avatin Ms. Erin Bennett BYK-Chemie USA : Post Office Box 5670 Wallingford, CT 06492-7651 • Dear Ms. Bennett: This is in response to your letter requesting clarification on shipping paper documentation requirements under Materials Regulations (HMR; 49 CFR Parts 171-180). In your letter the Hazardous you stated overpacks), each containing that your shipment contained two boxes (i.e., packaged in glass jars packed in expanded plastic boxes (4H1). I three different hazardous materials apologize for inconvenience. the delay and hope it has not caused you any An overpack is an enclosure protection or convenience used by a single consignor to provide consolidate two or more packages, (i.e., in handling a protective outer a package or to packaging such as shrinkwrapping, strapping, etc.). a box or crate, or secured to a pallet by Each inner expanded plastic box/package must be marked and labeled in accordance with " displayed on the overpack unless they the HMR and such marks and labels must be overpack. If each inner expanded plastic box is not marked and are visible through the labeled in compliance with the HMR, "then it is considered an inner packaging and the outer container must be in full compliance with outer container mut te ! the HMR, including being marked and labeled accordingly. The shipping papers must show a basic description entry for each of gross or net weight for each hazardous material must be shown on the three hazardous materials being shipped. In addition, the hazardous materials are packaged into each box. There is no requirement to indicate which However, for 172.202 : 172.207 173.25 : •#

Page 5• 2 clarification, containing..• then list each of the three hazardous it is recommended that you state "One box that box as separate entries on the shipping paper materials indicating the net weight of each material in the box. I hope this answers assistance, do not hesitate to contact us. your inquiry. If you need additional Sincerely, With ABiling, Delmer F. Billings Office of Hazardous Materials Regulations Development Standards .. ... .• .. .:#

Page 6': Marker HAZMATEAM, INC. Tell 172.300 :250 12 Kimball Hill Rd. HAZMAT Telephone (603) 882-6247 Hudson, NH 03051-3915 SC: 230, Fax (603) 882-6512 5/21/96 Hattie L. Mitchel, Chief Exemptions and Regulations Terminations Office of Haz Mat Standards 400 7th St. SW Washington, DC 20590 - Dear Hattie: Recently 171.8 definition section updated OVERPACK to include stretched wrapped material on a load board. At a chemical company I was asked if they had four different classes of materials on a pallet with markings and labels all visible from each different side, if labeling and marking the outside of the shrink wrap was necessary? ! Question I--Is it necessary to label and mark a shrink wrapped load board with each different class label and marker, if at each different side of the load board, the labels and markings are clearly visible on non-bulk packagings? Question 2-- Is it necessary to label and mark a shrink wrapped load board with each different class label and marker, if at each different side of the load board, the labels and markings are NOT clearly visible on non-bulk packagings? We would like a written answer. Thank you once again for your expertise. marina. m#

Page 7HAZMATEAM, INC. PM HAZMAT Hudson, NH 03051-3915 12 Kimball Hill Rd. 1985 Hattie L. Mitchel, Chief Exemptions and Regulations Terminations Office of Haz Mat Standards 400 7th St. SW Washington, DC 20590 • IL Inhaleshhhallonell - - - •--#