Interpretation Response #03-0112
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
June 5, 2003
Ms. Kathryn W. Pacha, CET, CIT Ref. No: 03-0112
140 Stoneridge Drive, Suite 500
Columbia, South Carolina 29210
Dear Ms. Pacha:
This is in response to your letter dated April 14, 2003 requesting clarification regarding the Class 7 (radioactive) materials marking requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically you ask whether a shipper is required to affix an additional marking on a package (i.e., "Type A" or "Type B "), as appropriate in accordance with § 172.310(b), if the manufacturer's marking in accordance with § 178.350(b) is clearly visible.
It is not necessary that package marking entries required by Part 172, Subpart D be separate and distinct from those specified in § 178.350(b). A packaging which is properly marked "USA DOT 7 A Type All would satisfy the requirements of § 172.310(b). Likewise, any proper shipping name containing the words "radioactive material," when entered with letters at least ~ inch high on a package of radioactive materials would also satisfy that portion of the packaging marking requirements of § 17~.350(b). A package merely marked "Type A" would not meet the requirements of § 178.350(b).
The requirement of § 172.310(b) applies not only to DOT 7 A packages but to Type B and foreign certified packages as well. It should not be considered to mean that the "USA" portion of the marking requirement specified in § 178.350(b) may be omitted on purely domestic shipments. However, the inscription "USA" need not appear twice on a DOT 7 A package destined for export.
I hope this satisfies your request.
Hattie L. Mitchell, Chief
Regulatory Review and Reinvention
Office of Hazardous Materials Standards
|§ 172.310||Class 7 (radioactive) materials|