Avonite, Inc. — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department Washington, D.C. 400 Seventh Street, S.W. 20590 Research and Administration Special Programs JUL 27 1999 Mr. Gilbert G. Espinoza Ref. No. 99-0064 Avonite, Inc. 1945 Hwy 304 Belen, NM 87002 Dear Mr. Espinoza: This is in response to your letter dated April 8, 1998, regarding dual markings on packages containing hazardous materials described as "Consumer Commodity, ORM-D" under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You requested our review of an enclosed drawing showing a package marked with "CONSUMER COMMODITY, ORM-D", "CONSUMER COMMODITY, ORM-D-AIR", "CONSUMER COMMODITY, ID 8000," and bearing a CLASS 9 label. The package is intended for transportation by highway, air, or vessel. The HMR do not prohibit more than one marking on packages containing hazardous materials. So as not to reduce the effectiveness of these markings, we suggest that the markings be placed on opposite: sides of the package. However, the orientation arrows depicted in your drawing do not conform pictorially to the ISO Standard 780-1985, as prescribed in 49 CFR 172.312. For your information, if all inner packagings meet 49 CFR 173.27, packages intended for materials described as "Consumer commodities, ORM-D," may be marked "ORM-D-AIR" regardless of whether they are transported by aircraft (See 49 CFR 172.316(a)(1) and 49 CFR 173.27). I hope this satisfies your inquiry. Sincerely, When Hillip Delmer F. Billings Chief, Standards Development Office of Hazardous Materials Standards 990064 172,301#

Page 2Engrum Avonite, Inc. 1945 HWY 304 PHONE # 505 864-3800 EXT 3038 BELEN, NM 87002 FAX* 505 864 7790 8172.301 00-0064 April 8, 1999 U.S. DOT ADMINISTRATION OFFICE OF HAZARDOUS RESEARCH & SPECIAL PROGRAMS 400 7TH ST S.W. MATERIAL STANDARDS (DHM-10) WASHINGTON, D.C. 20590-0001 Dear Helen ingrum: shipping Consumer Commodity shipments through Air, Ground, and Ocean shipments. Could you As you know we are currently looking at having our box manufacturer make 1 universal box for please comment on attached schematic, and make changes if need be! A large percent of these acceptable. shipments will be going UPS and Federal Express, please let me know if these packages will be Could you please fax over corrections/recommendations, along with supporting Regulations from: • CRR 49 PARTS 100 TO 185 • ICAO • IATA Thank you, Yelil Is. Epiz Gilbert G. Espinoza Traffic/Shipping Supervisor#