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Interpretation Response #03-0291 ([Unilever Home & Personal Care - USA] [Ms. Teresa L. Medley])

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

Interpretation Response Details

Response Publish Date:

Company Name: Unilever Home & Personal Care - USA

Individual Name: Ms. Teresa L. Medley

Location State: CT Country: US

View the Interpretation Document

Response text:

Jan 28, 2004


Ms. Teresa L. Medley                Reference No 03-0291
Director, Regulatory Affairs
Unilever Home & Personal Care - USA
75 Merritt Boulevard
Trumbull, CT 06611

Dear Ms. Medley:

This is in response to your letter requesting clarification of the marking requirements for packagings containing limited quantities and ORM-D materials under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).

As you are aware, in RSPA Docket HM-21511 (68 FR 44991) we added a new section, § 172.315, into the HMR that authorizes an alternative marking requirement for packagings containing limited quantities of hazardous materials.  This section allows limited quantity packagings to be marked with the ID number placed within a diamond.  This marking is optional and may be used in lieu of the marking requirements prescribed in § 172.301 (a).  Section 172.315 does not apply to packagings containing ORM-D materials.  The marking requirements in § 172.316 that apply to ORM-D materials remain unchanged.

I trust this satisfies your inquiry.



Hattie L. Mitchell
Chief, Regulatory Review and Reinvention
Office of Hazardous Materials Standards


Regulation Sections

Section Subject
172.316 Packagings containing materials classed as ORM-D