Federal-Mogul Power train Systems — Hazardous Materials Safety Interpretation

Page 110172.401 of Transportation U.S. Department aton, D.C. mth Street, S.W. . 20590 Research and Administration Special Programs JUL 2.6 1999 No. 0127 Mr. Scott Holder Federal-Mogul Powertrain Systems P.O. Box 910 Manitowoc, WI 54221-0910 Dear Mr. Holder: This is in response to Mr. Peter Madd Letter ding the requirements under the Hazardous Mate Regul ns (HMR; 49 CFR Parts 171-180) applicable to the f pain bbliterate labels on non-bulk packagings. Mr. reque that we address the response to you. Specifically, Mr. Madden asked whethe NuSe int to cover nonapplicable labels is accepta Or mus e label be removed. He stated that only require I'marki and labels would be visible on the packages. Th kages bin hazardous waste prepared for transpor in [dance with the provisions in SS 173.12 (c) and 17828(b) (6). The HMR does not prohibit the use of paint Completely obliterate nonapplicable labels. Suq happlia labels must be obliterated, removed or secut covered ing transportation. Markings and labels as for ertising are permitted, provided they do not 'confusion with any required marking or label. I hope this information is helpful. u. need *ther assistance, please do not hesttate to tact th ffice. Sincerely, Hothe "lo Hattie L. M Chi Regulatory and R ention 990127 Office of H ous Mati als Standards cc: Mr. Peter Madden 172.401#

Page 2é 16:47 CARDINAL ENVIRON INP. 02 CARDINAL Intere ENVIRONMENTAL 72. 401 May 17, 1999 99-0127 Mr. Edward Mazzillo U.S. Department of Transportation Director of Office of Hazardous Mare 400 7" Street, SW Washington, D.C. 20590 FAX: (202) 366-3012 Dear Mr. Mazzullo; RE: REQUEST FOR CLARINICATION: DRUMS USED POR SHIPMENT OF RDOUS NGM ON This letter is being written on behalf of ! P.O. Box 910, Manitoroc, Wisconsin, 94 address. 22120910. at thi Federal-Mogul oomplies with 49 FR 172, 2 (e), and time re-uisé of containers for the shipm the one practice to use spray paint, in a color t other information on a drum to be used 01 required DOT markings and labels are be the reviewing Federal-Mogul's practices in can not have labels that have been mat drum) removed De Since the masking of the unnecossary i the required DO'T markings, and there soo with mask the non-required data, the Federat paint to indicate in writing if this understandin If you have any questions, or need furt Intions 1224, and Mr. Holder can be reached at 7881 413- Thank you for your consideration. incerely Pet Maddi Peter Madden Operations Manager c: Scott Holder, FMPS 3303 Paine Avenu aboygan, 920/459-2500 FAX#