Interpretation Response #17-0011 ([Alchem Chemical Company] [Mr. Johnny Johnson])

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date: 04/25/2017

Company Name: Alchem Chemical Company

Individual Name: Mr. Johnny Johnson

Location State: GA Country: US

View the Interpretation Document

Response text:

April 25, 2017

Johnny Johnson
Alchem Chemical Company
5360 Tulane Drive, SW
Atlanta, GA 30336

Reference No. 17-0011

Dear Mr. Johnson:

This letter is in response to your January 31, 2017, e-mail and letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to general marking requirements for non-bulk packages. Specifically, you ask if the 12 mm height requirement is applicable to the UN identification number only, or if it applies to both the UN identification number and the proper shipping name.

This minimum height requirement for characters on a non-bulk package is applicable to the UN identification number only. According to § 172.301(a), the identification number (preceded by "UN," "NA," or "ID," as appropriate) must be marked in characters at least 12 mm (0.47 inches) high. Note that for non-bulk packages with a capacity of 30 liters (8 gallons) or less, the package shall be marked with characters at least 6 mm (0.24 inches) high.

The HMR do not specifically prescribe minimum height requirements for the display of the proper shipping name on a non-bulk package. If a non-bulk package displays characters using the minimum 12 mm or 6 mm height requirements as prescribed in § 172.301(a), the proper shipping name may be displayed in the same manner.

I hope this information is helpful. Please contact us if we can be of further assistance.

Sincerely,

Dirk Der Kinderen
Chief, Standards Development Branch
Standards and Rulemaking Division

172.301(a)

Regulation Sections