JL Shepherd & Associates — Hazardous Materials Safety Interpretation

Page 1U.S. Department 400 Seventh Street, S.W. of Transportation Washington, D.C. 20590 Research and Administration Special Programs DEC 2 8 1999 Ms. Mary F. Shepherd Ref. No. 99-0253 Vice President JL Shepherd & Associates 1010 Arroyo Ave.. San Fernando CA 91340-1822 Dear Ms. Shepherd: This is in response to your letter dated September 2, 1999, regarding the use of DOT Specification lA packagings that were designed in accordance with the requirements in effect on I am sorry for the delay and hope this has not caused you any inconvenience. Section 173.415 (a) states that "use of Specification 7A packagings designed in accordance with the requirements of $ 178.350 of this subchapter in effect on June 30, 1983... is not authorized after April 1, 1997." However, if it can be with the requirements of § 178.350 in effect on June 30, 1983, determined that a packaging originally designed in accordance meets the current requirements of 49 CFR 178.350, then the packaging would continue to be an authorized Type A packaging. I hope this satisfies your inquiry. Sincerely, The omar A. Allan Thomas G. Allan Senior Transportation Regulations Specialist Office of Hazardous Materials Standards 173.415 990253#

Page 2yale SHEPHERd & ASSOCIATES 3/73.415 IOIO ARROYO AVE., SAN FERNANDO, CALIFORNIA 91340-1822 99-0253 818-898-2361 FAX 818-361-8095 September 2, 1999 Director, Office of Hazardous Materials Standards Mr. Ed Mazzullo M/S DHM-10 U.S. Department of Transportation 400 7th St., S.W. Washington, D.C. 20509-0001 Dear Mr. Mazzullo: This letter is to request a written clarification on 49 CFR 173.415. lance with the requirements of 178.350 of this subchapter in effect on June 30, 1983 ... is no Section (a) of this paragraph states that "Use of Specification 7A packages designed in accor authorized after April 1, 1997." can be demonstrated to meet the October 1, 1982 revisions and current 1998 revisions. This paragraph does not permit the continued use of packages manufactured prior to this, if they We have received verbal confirmation from the RSPA that these packages may be used if it can be demonstrated that they meet all these revisions. We wish to receive written confirmation from the DOT that this indeed so. Thank you for your time and attention to this matter. Sincerely yours, J.L. SHEPHERD AND ASSOCIATES maryt. Shepherd Mary F. Shepherd Vice President CC: Dr. Fred Ferrate, RSPA, DOT#