Conley Corporation — Hazardous Materials Safety Interpretation

Page 1of Transportation US. Department Washington, D.C. 400 Seventh Street, S.W. 20590 Special Programs Research and Administration JUL 27 1999 Mr. Aaron Moran Ref. No. 99-0111 Shipping Manager Conley Corporation 2795 East 91st Street Tulsa, OK 74137 Dear Mr. Moran: This is in response to your letter dated April 29, 1999. Specifically, you ask how § 172.201 (c) of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) relates to the International Civil Air Organization's Technical Instructions For The Safe Transport of Dangerous Goods By Air (ICAO Technical Instructions). Section 172.201 (c) requires shipping papers that consist of more than one page to be consecutively numbered, and the first page must bear a notation of the total number of pages. Section 171.11 of the HMR authorizes the use of the ICAO Technical Instructions in lieu of the HMR for packaging, marking, labeling, classifying, and describing and certifying on a shipping paper hazardous materials which are transported by air. The ICAO Technical Instructions do not contain a requirement for Commercial enterprises that wish to impose additional notations on shipping papers that consist of more than one page. • requirements for transporting hazardous materials, such as numbering requirements on shipping papers being shipped under the provisions of the ICAO Technical Instructions are not precluded from doing so. The International Air Transportation Association Dangerous Goods Regulations (IATA) are intended for industry guidance among association members and are not official regulations. I hope this information is helpful. If you have further questions, please do not hesitate to contact this office. Sincerely, Delmer F. Billings Chief, Standards Development Office of Hazardous Materials Standards 172.20) 990111#

Page 2APR-29-1999 16:40 CONLEY CORPURATION Attention Edward Mazzullo FAX: 202-366-3012 Company: Conley Corporation. Stevens м... _ Address: 2795E. E. 91st Tulsa, OK OK_74137 3172.201 Phone: 918-299-5054 99-0111 Fax 918-299-5907 ... • c Please define regulation 172.201 (c) in reguards to applicablility concerning IATA. The regulation stated within IATA refers to the fact that the shipping declaration 4AN. man. mama ... -- must state one of one and not be listed as a continuation page. They have refused shipments listed as continuation pages. мален.. Sincerely._ Aaron R. Moran/Shipping Manager Lu- TOTAL P.Ø1#