Interpretation Response #04-0083
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Apr 19, 2004
Ms. Connie Barron Reference No. 04-0083
Export Distribution Supervisor
Mallinckrodt Baker Inc.
7001 Bypass Road
Paris, KY 40361
Dear Ms. Barron:
This responds to your March 18, 2004 letter requesting clarification on the requirement to mark limited quantity packages with the UN identification number within a diamond under section 22.214.171.124 of the International Maritime Dangerous Goods (IMDG) Code. Specifically, you ask whether the IMDG Code requires packages containing limited quantities to be marked with the UN identification number placed within a diamond as specified in 126.96.36.199 of the IMDG Code.
The answer is yes. Section 188.8.131.52 of the IMDG Code states that limited quantity packages need not be marked with the proper shipping name but, must be marked with the UN identification number placed within a diamond. In your letter you note that § 172.315 of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) allows the UN identification number within a diamond marking as an option but does not require it if the proper shipping name is marked on the box. You ask whether the intent of the IMDG Code is to also allow a similar alternative. No similar alternative exists in the IMDG Code. However, limited quantities of dangerous goods for personal or household use that meet the provisions of section 3.4.7 of the IMDG Code are not required to be marked with the UN identification number within a diamond.
I hope this answers your inquiry.
John A. Gale
Chief, Standards Development
Office of Hazardous Materials Standards
|§ 172.315||Limited quantities|