Interpretation Response #03-0237 ([The Sherman-Williams Company] [Ms. Sandra L. Basham])

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

Interpretation Response Details

Response Publish Date: 10/09/2003

Company Name: The Sherman-Williams Company

Individual Name: Ms. Sandra L. Basham

Location State: OR Country: US

View the Interpretation Document

Response text:

Oct 9, 2003

Ms. Sandra L. Basham               Reference No. 03-0237
Director of Transportation Corporate
Regulatory Affairs
The Sherman-Williams Company
101 West Prospect Avenue
Cleveland, OR 44115-1075

Dear Ms. Basham:

This is in response to your letter dated September 16, 2003 regarding the limited quantity marking requirements found in Part 172, Subpart D of the Hazardous Materials Regulations (HMR: 49 CFRParts 171-180). Specifically, you ask if a package marked with the identification number inside a white square-on-point configuration and the term "LIMITED QUANTITY" would fulfill the marking requirements for packages containing limited quantities of hazardous materials.

Your example fulfills the requirements of § 173.315, which permits a shipper to mark the package with the identification number inside a white square-on-point configuration to identify the material as a limited quantity. Further, placing the term "Limited Quantity" on the packaging is neither required nor prohibited under § 172.303. Therefore, marking the term "LIMITED QUANTITY" on the package as shown in your example is acceptable. Note, however, that, in order for your example to fulfill the requirements of Part 172, Subpart D, additional packaging markings are required. At the very least, the package must be marked with the consignee's or consignor's name and address under § 172.301 (d) and, possibly, packaging orientation arrows under § 172.312.

I hope this satisfies your request.

Sincerely,

Susan Gorsky
Senior Transportation Regulations Specialist
Office of Hazardous Materials Standards

Regulation Sections