Sakai Trading New York Inc. — Hazardous Materials Safety Interpretation

Page 1US. Department of Transportation Washington, D.C. 400 Seventh Street, S.W. 20590 dministration MAR 2 9 1999 Mr. I. Goto Sakai Trading New York Inc. Ref. No. 99-0026 317 Madison Avenue, #1601 New York, NY 10017 Dear Mr. Goto: This is in response to your letter dated January 26, 1999, concerning the display of bilingual text on hazard warning labels under the Hazardous Materials Regulation (HMR; 49 CFR Parts 171-180). Specifically, you ask whether it is permissible to use another language, in addition to English, for the text on labels. The answer is yes. Labels conforming to provisions in the : United Nations Recommendations may be used in place of the corresponding labels under the HMR. Paragraph 5.2.2.2.1.6 of the United Nations Recommendations (10"h Revised Edition), in limiting text placed on labels to "particulars. indicating the nature of the risk and precautions in handling," implies that BESE bilingual inscriptions or text indicating the nature of the However, we interpret this provision as being limited to those inscriptions authorized by a competent authority. On this basis, if the Japanese government requires I hope this satisfies your request. Sincerely, Transportation Regulations Specialist Office of Hazardous Materials Standards 172.407#

Page 2JAN. 26.19991:42PM SAKAI TRADING NY NO. 2565 P. 1 SAKAI TRADING NEW YORK INC. PHONE: 212-588-1930 317 MADISON AVENUE NEW YORK, N.Y. 10017 FACSIMILE: 212-699-1550 PX/3 BAH January 26, 1999 172.407 U.S. Department of Transportation Attr: Mr. Edward Mazzullo RSPA Harzardous Material Standard 400, 7th Street S.W. Washington, D.C. 20590 Subject: Bilingual Hazardous Label for imported Chemical ABN-R (2,2 Azobisisobutyronitrile) Gentlemen: The subject chemical imported under DOT's permission with hazardous warning label shown on on each drum and outer container for in transit as Flammable Solid Class 4. The label is shown in bilingualbasis (both English and Japanese, see attached) due to the hazardous control in Japan also required such label. In doing so, we therefore, anxiously ask your favor to interpret in accordance with DOT regulation, to determine whether the above mentioned bilingual label is permissible by Federal or not in conflict with state or lacal citation which disapprove the bilingual label? regulation? The said label has violated any of DOT regulation? If not, Federal regulation prevail solve the above mentioned problem. Kindly reply by sending your valuable interpretation to us by fax (212) 599-1536, to allow us to Thank you very much. Respectfully Submitted, Sakai Trading New York Inc. Raisahe Sitt 94. GoteT Sales Manager#

Page 3of Transportation U.S. Department 400 SeNion, D550 Research and Administration Special Programs MI: J.A. Roberts Dyes and Pigments Division Import/Export Supervisor MAR - 9 1984 P.O. Box Mobay Chemical Corporation Union, New Jersey 385 07083 • Dear Mr. Roberts: This is in response to your letter dated February concerning the printing of proper shipping names and identifica- 29, 1984, tion numbers on hazard warning labels. You are correct in your understanding that proper shipping names within the 1/4 inch border of a label. and UN or NA identification numbers may not be printed or written 49 CFR 172.407(c), a label Under the requirements of Part 172. The only printing permitted on a label, other than the must appear "as shown" in Subpart E of symbol and hazard warning, the UN hazard class number is form identification (see paragraphs (f) and (g) of 49 CFR information and 172.407). The proper shipping name and identification number displayed outside of the • 1/4 inch seen on the may enclosed literature from a label manufacturer. I trust this satisfies your inquiry. If we can be of further assistance, please contact us. sincerely,, Chief, Office of Hazardous Materials standards Divis10l Regulation Materials Transportation Bureau Enclosure : -#