Amrep, Inc. — Hazardous Materials Safety Interpretation

Page 1- 400 Seventh Street. S.W Washington, D.C 20590 FEB 1 2000 Mr. Darran T. Chase Ref. No: 99-0325 Environmental Affairs Manager Amrep, Inc. 990 Industrial Park Drive Marietta, Georgia 30062 Dear Mr. Chase: This is in response to your letter of November 30, 1999, requesting clarification of exemption DOT-E 10232. Your understanding is that a copy of the exemption must be kept on file but that the exemption number does not have to be printed on the side of the package and that the exemption does not have to accompany the package when the hazardous material has been properly classed as ORM-D. You are correct that this exemption specifically states that a material that has been classed as a "Consumer commodity, ORM-D" is excepted from marking the exemption number on the outer packaging. In addition, a copy of the exemption must be maintained at each facility where the package is offered or reoffered and at each facility where the packaging is being used in connection with the transportation of a hazardous material. However, your understanding that a copy of the exemption is not required to "accompany" the package is incorrect. As provided by paragraph 10 of DOT-E 10232, a current copy of the exemption must be carried aboard each motor vehicle used to transport packages covered by this exemption. I hope this information is helpful. Sincerely, man Hello Delmer F. Billings Chief, Standards Development Office of Hazardous Materials Standards 990325 IZUONI#

Page 2Lavalle Aamrep 1240 est 99-0525 November 30,1999 Director of Hazard Materials Standards Edward Mazzullo (OHMS) (DHM-10) US DOT/RSPA Washington, 20590 400 7* St. S.W. RE: DOT-E 10232 Dear Mr. Mazzullo, I am writing for a clarification and a CFR regulation which would confirm the following information. One of my customers, during a routine DOT inspection was cited for shipping materials, purchased from us information with each package. that contained packaging using the exemption listed above, and not providing a copy of the exemption I understand when using an exemption that a copy of the exemption must be kept on file. However accompany the package if it falls within the guidelines of a "Consumer Commodity". according to verbiage stated in the exemption that documentation does not have to be printed on the side or Can you provide some clarification on this matter? If I can help with the process, please do not hesitate to call me at (770) 767-2037. Sincerely, Jarran I. Chas Environmental Affairs Manager Amrep, Inc. • 990 Industrial Park Drive • Marietta, Georgia 30062 • 770/422-2071 800/66-AMREP • Fax: 770/422-1737#