Interpretation Response #04-0048 ([Mallinckrodt Baker, Inc.] [Mr. Harold Broeckel])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Mallinckrodt Baker, Inc.
Individual Name: Mr. Harold Broeckel
Location State: NJ Country: US
View the Interpretation Document
Response text:
Dec 15, 2004
Mr. Harold Broeckel Reference No. 04-0048
Senior Packaging Engineer
Mallinckrodt Baker, Inc.
600 N Broad Street
Phillipsburg, NJ 08865
Dear Mr. Broeckel:
This is in response to your letter requesting clarification of the applicability of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) to the transportation of a hazardous material in a dual-marked package authorized under exemption. We apologize for the delay and hope it has not caused you any inconvenience. Specifically, you asked whether if it is permissible to use a package dual-marked
(e.g. UN4G/X1.7/DOT-E8230) for a hazardous material not referenced in the exemption.
The answer is yes, provided that the packaging meets the requirements of the exemption and the UN packaging standard in all respects. The prohibited marking requirements in
§ 172.303 do not require the removal or obliteration of the exemption number from the packaging even when the packaging is not being used under the terms of the exemption. However, in order to minimize confusion or frustration of the shipment, you may wish to cover or obliterate the exemption number marking when the packaging is not being used under the terms of the exemption.
I hope this information is helpful. Please contact us if you require additional assistance.
Sincerely,
John A. Gale
Chief, Standards Development
Office of Hazardous Materials Standards
178.3 (c)