Autoliv ASP, Inc. — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation 400 Seventh Street, S.W. Research and Washington, D.C. 20590 Special Programs Administration MAY | 4 1998 Mr. Terry Zost Manager, Logistics Services Autoliv ASP, Inc. 3350 Airport Road Odgen, Utah 84405 Dear Mr. Zost: This is in response to your letter dated January 21, 1998, regarding the definition of an overpack. Specifically, you ask if two or more packages are considered overpacked if they are secured to a wooded pallet by metal or composite banding. The Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) define an overpack in § 171.8 as an enclosure that is used by a single consignor to provide protection or convenience in handling of a package or to consolidate two or more packages. Section 171.8 provides the following examples of overpacks: (1) one or more packages placed or stacked onto a board such as a pallet and secured by strapping, shrink wrapping, stretch wrapping or other suitable means; or (2) one or more packages placed in a protective outer packaging such as a box or a crate. It is the opinion of this Office that the packaging scenario provided in your letter constitutes an overpack in accordance with both the HMR and the International. Civil Aviation Organization's Technical Instructions for the Transport of Dangerous Goods by Air. I hope this satisfies your request. Sincerely, Delmer F. Billings Chief, Standards Division Office of Hazardous Materials Standards#

Page 2• Jale Ill: 173.25 388 Autoliv 21 January 1998 9520-FY-006 SC 346, U.S Department of Transportation Research and Special Programs Administration Office of Hazardous Materials Standards 400 Seventh Street, SW Washington, DC Attention: Mr. Edward Mazzullo, Director Subject: Request for Interpretation, Overpack References: (A) Title 49 CFR Section 171.8 (B) Memo BAX Global (C) IATAICAO Dear Mr. Mazzullo: • As you know, reference (A) defines an Overpack, in part as "(1) Placed or stacked onto a load board such as a pallet and secured by strapping, shrink wrapping, stretch wrapping or other suitable means;" This definition, according to reference (B), is in direct conflict with reference (C) which defines an overpack as "An enclosure used by a single shipper to contain one or more packages and to form one handling unit for convenience of handling and storage." Autoliv ASP has requirements to ship two or more packages, via Air, on a wooden pallets secured by metal or composite banding. In our view these shipments would qualify as overpacks. Autoliv ASP respectfully requests DOT interpretation as to whether or not this method qualifies as an overpack. If there is any additional information we can provide please feel free to call Mr. Glen Wanczyk at 801 625 9543 or Fax 801 625 7012. Very truly yours, Ten 2Zos lerry Manager, Logistics Services Attachment: Memo from Bax Global Copy to: IATA Mr. Shawn Gerber TRW Mr. Mike King BAX Global Mr. Bill Hampton Autoliv ASP, Inc. Ogden, Utah 84405 3350 Airport Road ax: (801) 625-491 hone: (801) 625-480#

Page 3**** ADM **** MSG#: M13J#12918. AUTOLIV-AND-OVERPACK ARGUS+ MESSAGE (SNDM) DEST: SLCE ORIG: BDGA ATTN: STEVE KINGHORN SUBJ: AUTOLIV AND OVERPACKS FROM: RUSS BOWEN BY: BDGRAB1 AT: 14:26 13JAN98 BAX POLICY ON OVERPACKS UNDERSTANDING THAT AN OVERPACK IS NOT MEANT IO ADD ANY ADDITIONAL INTEGRITY AS RESENCED THE EATA DOR IN THE GIOSAY. BAOTIC CANOE ME FEE FRET MATERIAL MEETS TWO WORDS OF THE. DEFINITION, "AN ENCLOSURE". THE USA GOVERNMENT HAS STATED OVERPACK AS LONG AS ALL OF THE PACKAGES ARE SURROUNDED BY THE SHRINK WRAP, BUT WAS INTERESTINGLY MUTE ON THE SUBJECT OF BANDING. WE ALL KNOW THAT THE MATERIAL FOR AN OVERPACK AS LONG AS IT "ENCLOSES" THE PACKAGES. IF THERE IS NOT CLEAR VISIBILITY IO THE PACKAGES CONTAINED IN AN OVERPACK, THEN THE LABELS AND MARKINGS ON THE PACKAGES WITHIN THE OVERPACK MUST BE SPECIFICATION PACKAGES, AND IF THE SPECIFICATION MARK IS NOT VISIBLE, THEN REPRODUCED ON THE OUTSIDE OF THE OVERPACK. IF THE OVERPACK CONTAINS "UN" APPEAR ON THE OVERPACK USED TO ENCLOSE THESE PACKAGES. THE STATEMENT "INNER PACKAGES COMPLY WITH PRESCIRBED SPECIFICATIONS" MUST REGARDS, RUSS ****#