Bell Helicopter TEXTRON — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Research and special Programs Administration : AUG 1 O 1999 Mr. Albert Alva Ref No. 99-0125 Bell Helicopter TEXTRON Post Office Box 482 Forth Worth, Texas 76101 Dear Mr. Alva: This is in response to your letter dated March 13, 1999, regarding whether your understanding is correct that under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) an existing fiberboard box (UN 4G) may be retaped with your company's tape. You stated that your company, Bell Helicopter, receives numerous hazardous materials in UN 4G fiberboard boxes from various manufacturers, which are opened and inspected and then retaped and shipped to another customer. The inner packagings and cushioning material, if present, is not changed or altered. Under the notification provision of 49 CFR 178.2(c), the manufacturer and each subsequent distributor of a UN packaging must provide written instructions to customers of all regulatory requirements not met at time of transfer, such as instructions on how to properly assemble and close a packaging (e.g., UN 4G fiberboard box). Therefore, the tape used to reclose a package that has been opened must be the type specified in the closing instructions. In addition, the package may not be damaged by original opening There is no limitation on who may reuse a packaging for the transportation of hazardous materials. The person who reuses the packaging does not have to be the original user. The reuse provisions in 49 CFR 173.28 must be met for a packaging manufactured to a UN standard (e.g., UN 4G). A UN 4G fiberboard box may be reused subject to the conditions and limitations of that section. I hope this satisfies your inquiry. If we can be of further assistance, please contact us. Sincerely, Delmer F. Billings Chief, Standards Development Office of Hazardous Materials Standards 113,28 990125#

Page 205/13/99 11:36 SHIPPING DEPT 31 9 9512020000016 Engrum Bell Helicopter TEXTRON 8173,28 Subsidiary of Textron In Jell Holicopter Toxtron Inc Post Office Box 482 817) 280201103 7610 5/13/99 TO: Ed Mazzullo Director, OHMS Department of Transportation FROM: Albert Alva Bell Helicopter Textron CC: Billy Townsley Bell Helicopter Textron SUBJECT: Reuse of Existing 4G Packaging REF: Paragraph 173.28 Bell Helicopter receives numerous hazardous material packages in (4G) fiberboard boxes from . various manufacturers. In some instances, the item is opened and inspected, after which the package is retapped and shipped to another customer. The inner packaging(s) and cushioning material, if present, is not changed or altered. The question has come up regarding retapping the fiberboard box. Per a recent conversation with Arthur Pollack, DOT Information Center, it is our understanding that Bell Helicopter is allowed to retape the existing fiberboard box with our own tape, however, if a particular tape is specified on the package, that tape should be used. Please verify that Bell Helicopter's understanding of retapping existing packaging is correct. Send responses to the undersigned. Ausso AwA Albert Alva Sr. Material Handling/Packaging Engineer 817-280-4275 817-280-3073 fax aalva@bellhelicopter.textron.com Post-ite Fax Note 7671 Data 5/13/99 pages / TO ED MAZZULLO FOm ALBERT ALVA Co. BELL HELICOPTER phono: 202-346-4488 phone # 817-280-4275 FarR 202-366-3012 Faxe 817-280-3073#