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Interpretation Response #03-0076 ([Yellow Freight System] [Mr. Robert A. Maberry III])

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

Interpretation Response Details

Response Publish Date:

Company Name: Yellow Freight System

Individual Name: Mr. Robert A. Maberry III

Location State: KS Country: US

View the Interpretation Document

Response text:

Apr 11, 2003


Mr. Robert A. Maberry III               Reference No. 03-0076
Yellow Freight System
P.O. Box 7270
Overland Park, KS 66207

Dear Mr. Maberry:

This is in response to your letter dated February 26, 2003, regarding marking and labeling requirements and exceptions for Cartridges, small arms and Smokeless power under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Specifically, you asked does the HMR allow a shipper to offer Cartridges, small arms, UN0012, that have been reclassed and offered for transportation as Cartridges, small arms, ORM-D, to display dual markings?  Your questions are paraphrased and answered as follows:

QI.       Does the HMR allow a shipment of Cartridges, small arms, UN0012, II, reclassed as Cartridges, small arms, ORM-D, to display dual markings?

Al.        The answer is yes.  These packages may contain multiple (international and domestic U.S.) markings and labels.  For international transport, each package of cartridges would be marked “Cartridges, small arms, UN0012, II”, and labeled “1.4S”, and for domestic U.S. transport, each package would be marked “Cartridges, small arms, ORM-D.” As prescribed in § 173.63 (b), small arms cartridges which have been classed as a Division 1.4S explosive may be reclassed, offered for transportation, and transported as ORM-D material when packaged in accordance with § 173.63 (b) (2).

Q2.      In accordance with § 173.171 of the HMR, can shipments of “Power smokeless, 1.3, UN0161, I”, reclassed in Division 4.1 (Smokeless power for small arms, 4.1, NA3178, I), display dual markings?

A2.      The answer is yes.  See answer Al.

I hope this information is helpful.  Please contact us if you require additional assistance.



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


Regulation Sections

Section Subject
172.301 General marking requirements for non-bulk packagings