Interpretation Response #04-0069 ([NOVA Chemicals Corporation] [Mr. Kevin Duncan])

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

Interpretation Response Details

Response Publish Date: 07/13/2004

Company Name: NOVA Chemicals Corporation

Individual Name: Mr. Kevin Duncan

Country: CA

View the Interpretation Document

Response text:

Jul 13, 2004

Mr. Kevin Duncan                Reference No. 04-0069

Global Packaged and Export Leader

NOVA Chemicals Corporation

1000 Seventh Avenue S.W.

P.O. Box 2518, Station M

Calgary, Alberta, Canada, T2P 5C6

Dear Mr. Duncan:

This is in response to your April 28, 2004 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to labels. Specifically, your inquiry concerns whether an identification number and a hazard warning label affixed to a flexible intermediate bulk container are required by the HMR to face outwards (i.e., towards the door) when loaded into an enclosed transport vehicle or freight container.

The HMR do not specifically address the visibility of package markings and labels when loaded into an enclosed transport vehicle or freight container. However, placing packages in a transport vehicle in a manner that makes it difficult for carrier personnel or enforcement personnel to determine whether the package conforms to marking and labeling provisions may result in delays or frustration of shipments.

I hope this information is helpful.

Sincerely,

John A. Gale   

Chief, Standards Development

Office of Hazardous Materials Standards

172.406

Regulation Sections