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Interpretation Response #02-0285 ([ArthurP. Hancock])

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

Interpretation Response Details

Response Publish Date:

Company Name:

Individual Name: ArthurP. Hancock

Country: US

View the Interpretation Document

Response text:

Nov 23, 1998

Arthur P. Hancock                 Reference No. 02-0285

42 Gorse Road

Cookham, Berks SL6 9LL


Dear Mr. Hancock:

This is in response to your facsimile of November 16, 1998, concerning a new requirement for limited quantities of dangerous goods introduced into the European road and rail regulations for transporting dangerous goods (ADR/RID).  The new requirements (e.g., marginal 2301a of the ADR), which become effective on January 1, 1999, are for a diamond shaped label to appear on packages of limited quantities of dangerous goods.  The label is to bear the United Nations number of the item of dangerous goods contained in the package or the letters "LQ" when more than one item of dangerous goods is in the package.  You asked whether packages so labeled would be acceptable for transport in the United States.

We consider packages so labeled to be unacceptable for transport in the United States.  The US Hazardous Materials Regulations (HMR) in Title 49 of the Code of Federal Regulations in 172.401(b) prohibits labeling "which by its color, design, or shape could be confused with a label prescribed" by the HMR.  In our opinion, the labeling required by the new ADR/RID requirements could be so confused.  Therefore, such labeling is prohibited from use in the United States.


Frits Wybenga,

International Standards Coordinator

for Hazardous Materials Safety


Regulation Sections

Section Subject
172.401 Prohibited labeling