BP Oil Company — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation 400 Seventh Street, S.W Washington, D.C. 20590 Research and special Programs Administration APR 2 2 1999 Mr. J. J. Quandt BP Oil Company Ref. No. 99-0039 200 Public Square Cleveland, OH 44114-2375 Dear Mr. Quandt: This regarding requirements to identify marine pollutants on is in response to your letter dated February 1, 1999, shipping papers under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). describe leaded gasoline on a shipping paper as "Gasoline Specifically you ask if you may (Leaded), 3, UN1203, PG II, Marine Pollutant." answer is yes. Section 172.203(1) (1) states that if a proper shipping name for a material that is a marine pollutant the name of that component must appear in parentheses in does not identify the component making it a marine pollutant;, association with the basic description. "Gasoline" and the description "Marine Pollutant" which appear The shipping name the marine pollutant "Gasoline, leaded." as part of the shipping description are sufficient to identify this office that the description "Gasoline, (leaded), 3, It is the opinion of description for leaded gasoline. UN1203, PG II, Marine Pollutant" is also an acceptable I hope this satisfies your request. Sincerely, nast Delmer F. Billings Chief, Office of Hazardous Materials Standards Development Standards 990039 172.203#