General Services Administration — Hazardous Materials Safety Interpretation

Page 1of Transportation US. Department 400 Seventh Street, S.W. Washington, D.C. 20590 Special Programs Research and Administration AUG 6 1999 Mr. Bob Burnett Ref. No. 99-0181 General Services Administration Bidg. 412-A Rough & Ready Island Stockton, CA 95203 Dear Mr. Burnett: This is in response to your letter dated June 29, 1999, requesting clarification of a proper shipping description under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you asked if it was permissible for a coating kit containing two receptacles of coating solution, one classified as packing group (PG) II and the other classified as PG III, to be described under one shipping description as a PG II material. The answer is no. A Class 3, PG III material may not be described on a shipping paper as a PG II material. In the scenario you describe, the PG II and PG III coating solution should be described separately on your shipping paper. I hope this satisfies your request. Sincerely, besi / Transportation Regulations Specialists Office of Hazardous Materials Standards 990181 172.202#

Page 2WESTERN DISTRIBUTION CENTER BLDG. 412 ROUGH AND READY ISLAND BON STOCKTON, CA • 95203 *ADMINISTRATION * GENSRAL SERVICES 172.202 99-0181 June 29, 1999 TO: Hazardous Materials, D.O.I. FROM: Bob Burnett General Services Administration Bldg 412-A Rough & Ready Island Stockton Ca 95203 SUBJECT: Description of hazardous materials We have a coating kit being shipped to us that contains Paint, 3, UN1263 with equal quantities (3.8L) Of packing group II and III. They have chosen to describe this material as 7.6 L of packing group II and ignore the group III. Is this permissible to describe as such, or must each i be considered a Proper Shipping Name? Your help is greatly appreciated#