Interpretation Response #03-0238 ([Exide TecImologies] [Mr. David M. Bloom])

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

Interpretation Response Details

Response Publish Date: 10/17/2003

Company Name: Exide TecImologies

Individual Name: Mr. David M. Bloom

Location State: GA Country: US

View the Interpretation Document

Response text:

Oct 17, 2003

Mr. David M. Bloom               Reference No. 03-0238
Manager-Environment, Health and Safety
Exide TecImologies
13000 Deerfield Parkway
Building 200
Alpharetta, GA 30004

Dear Mr. Bloom:

This is in response to your September 15, 2003 letter, requesting clarification of the Hazardous Materials Regulations (HMR; 49 CPR Parts 171-180) applicable to orientation arrows. Specifically, you ask if orientation arrows on non-hazardous packages are prohibited, and if the display of orientation arrows necessarily indicates the presence of hazardous materials.

The answer is no. The arrows are a communication requirement that tells the handler of the package the correct orientation for transportation. In accordance with § 172.312, liquid hazardous materials in non-bulk packagings must be marked with package orientation markings that conform pictorially to ISO Standard 780-1985, on two opposite vertical sides of the package with the arrows pointing in the correct upright direction. Depicting a rectangular border around the arrows is optional. Arrows for purposes other than indicating proper package orientation may not be displayed on a package containing a liquid hazardous material. There is nothing in the regulations prohibiting the use of these arrows for other packagings. Therefore, they can be used in any manner for shipments of solids and non-hazardous materials.

I hope this satisfies your inquiry.

Sincerely,

Susan Gorsky
Senior Transportation Regulations Specialist
Office of Hazardous Materials Standards

Regulation Sections