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Interpretation Response #00-0027 ([Regulatory Center of Excellence] [Mr. William 0. Gramer])

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

Interpretation Response Details

Response Publish Date:

Company Name: Regulatory Center of Excellence

Individual Name: Mr. William 0. Gramer

Location State: MN Country: US

View the Interpretation Document

Response text:

January 27, 2000

Mr. William 0. Gramer                 Ref. No. 00-0027
3M Package Engineering,
Regulatory Center of Excellence
3M Center 224-1 E-09
St. Paul, MN 55144-1 000

Dear Mr. Gramer:

This is in response to your letter regarding the orientation arrow markings that are required on certain packages of liquid hazardous materials under the Hazardous  Materials Regulations (HMR; 49 CFR Parts 171-180).  Specifically you ask whether § 172.312 prohibits the placement of arrows for purposes other than orientation on packages containing liquid hazardous materials.

The answer is yes.  As provided by § 172.312, each non-bulk combination package having inner packagings containing liquid hazardous materials must be packed with closures upward, and legibly marked with package orientation markings.  Additionally, arrows for purposes other than indicating proper orientation may not be displayed on a package containing a liquid hazardous material.

I hope this information is helpful.

Sincerely,

Delmer F. Billings
Chief, Standards Development
Office of Hazardous Materials Standards

172.312

Regulation Sections

Section Subject
172.312 Liquid hazardous materials in non-bulk packagings