Interpretation Response #06-0050 ([REG Scan] [Mr. Russ Shanahan])

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

Interpretation Response Details

Response Publish Date: 03/31/2006

Company Name: REG Scan

Individual Name: Mr. Russ Shanahan

Location State: PA Country: US

View the Interpretation Document

Response text:

Mar 31, 2006

Mr. Russ Shanahan                 Reference No. 06-0050
REG Scan
800 West Fourth Street
Wiliiamsport, PA 17701

Dear Mr. Russ Shanahan:

This responds to your letter dated February 14, 2006 regarding the marking requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) as they apply to the display of identification number marking on a closed transport vehicle containing multiple bulk packages.

Q1.  Are two “UN1 993” identification number markings required to be displayed on a closed transport vehicle containing two bulk packagings of a material described as “Flammable liquid, n.o.s., 3, UN 1993, PG 1.”

Al.  For a bulk packaging contained in or on a transport vehicle or in a freight container, if the identification number marking on the bulk packaging is not visible, the transport vehicle or freight container must be marked on each side and each end with the identification number specified for the material in the § 172.101 Table (See § 172.332).

As specified in § 172.302(a), a bulk packaging must be marked with the identification number and displayed as required by § 172.332 on each side and each end of the bulk packaging, if the capacity of the packaging is 3,785 L (1,000 gallons) or more, or on two opposing sides, if the packaging has a capacity of less than 3,785 L (1,000 gallons). Additional requirements for marking bulk packagings, such as a portable tank, cargo tank, tank car and multi-unit tank car tank,, and other bulk packaging (e.g., IBCs) are prescribed in § 172.326, 172.328, 172.330 and 172.331, respectively.

Q2.  Would the answer to “Q1” change if the products had the same technical names?

A2.  No.

Q3.  Are the two identification number markings, “UN1993” and “NA1993”, required to be displayed on a closed transport vehicle containing two bulk packagings of
materials described as “Flammable liquid, n.o.s., 3, UN 1993, PG 1” and “Combustible liquid, n.o.s, Combustible liquid, NA 1993, PG III.”

A3.  See answer “Al”. In this case, the identification numbers are essentially the same. The marking “UN 1993” is used for both domestic and international transportation, while the marking “NA1993” may only be used for domestic transportation. Each bulk packaging must be placarded in accordance with § 172.504.

I hope this information is helpful. If we can be of further assistance, please contact us.

Sincerely,

John A.Ga1e
Clef, Standards Development
Office of Hazardous Materials Standards

172.302, 172. 331

Regulation Sections