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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #01-0316 ([UPS Corporate Hazardous] [Ms. Mary Beth])

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

Interpretation Response Details

Response Publish Date:

Company Name: UPS Corporate Hazardous

Individual Name: Ms. Mary Beth

Location State: GA Country: US

View the Interpretation Document

Response text:

December 27, 2001

 

Ms. Mary Beth Schommer                 Reference No. 01-0316
UPS Corporate Hazardous
  Materials Manager
55 Glenlake Parkway NE
Atlanta, GA 30328

Dear Ms. Schommer:

This is in response to your letter dated December 18, 2001 requesting a review of your proposed shipping labels for compliance with the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Specifically, you ask if the incorporation of the ORM-D markings into the UPS bar coded address label will meet the marking requirements under the HMR.  You provided three examples of UPS bar coded address labels containing the ORM-D markings.

The answer is yes.  Section 172.304(a)(4) states that the required marking (proper shipping name and identification number) must be located away from any other marking (such as advertising) that could substantially reduce its effectiveness.  The required markings appearing on your enclosed labels are readily distinguishable and satisfy this requirement.

I hope this satisfies your request.

Sincerely,

 

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

172.304

Regulation Sections

Section Subject
172.304 Marking requirements