Interpretation Response #14-0226 ([ARKEMA Inc.] [Ms. Christina Kurtz])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: ARKEMA Inc.
Individual Name: Ms. Christina Kurtz
Location State: PA Country: US
View the Interpretation Document
Response text:
February 18, 2015
Ms. Christina Kurtz
Manager Hazmat Regulations and Packaging
ARKEMA Inc.
900 First Avenue
King of Prussia, PA 19046-1308
Reference No. 14-0226
Dear Ms. Kurtz:
This is in response to your November 28, 2014 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) relating to the orientation of a marine pollutant marking placed on a package. Specifically, you ask if the marking may be placed on a package with the flat sides parallel to the package.
While it is the intent of the regulations that the marking be oriented square-on point on a package when possible, the requirements in § 172.322 of the HMR, Part 5;2.4.9 of the International Civil Aviation Organization’s Technical Instructions for the Safe Transport of Dangerous Goods (ICAO TI) and Chapter 5.2.1.6 of the International Maritime Dangerous Goods (IMDG) Code do not prohibit the placement of the marking in an orientation where the square-on-point is located with its flat sides parallel to the package.
I trust this information is helpful. If you have further questions, please do not hesitate to contact this office.
Sincerely,
Duane A. Pfund
International Standards Coordinator
Standards and Rulemaking Division
172.322
Regulation Sections
| Section | Subject |
|---|---|
| 172.322 | Marine pollutants |