Interpretation Response #04-0123 ([H.B. Fuller Company] [Mr. Eugene J. Secor])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: H.B. Fuller Company
Individual Name: Mr. Eugene J. Secor
Location State: MI Country: US
View the Interpretation Document
Response text:
Jun 3, 2004
Mr. Eugene J. Secor Reference No. 04-0123
EHS/Transportation Specialist
H.B. Fuller Company
31601 Research Park Drive
Madison Heights, MI 48306
Dear Mr. Secor:
This is in response to your May 5, 2004 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to package orientation arrows. Specifically, you ask whether the orientation arrows preprinted on your non-specification fiberboard boxes used for limited quantities of hazardous materials as shown in your accompanying photograph meet the requirements of § 172.312 of the HMR.
The answer is no. Section 172.312 of the HMR requires each non-bulk combination package having inner packagings containing liquid hazardous materials be legibly marked, with package orientation markings that conform pictorially to the illustration shown in this section, on two opposite vertical sides of the package with the arrows pointing in the correct upright direction. Depicting a rectangular border around the arrows is optional. The package orientation arrows as displayed on your fiberboard boxes in your photograph do not conform pictorially to the illustration in § 172.312.
I hope this information is helpful.
John A. Gale
Chief, Standards Development
Office of Hazardous Materials Standards
172.312(a)(2)
Regulation Sections
| Section | Subject |
|---|---|
| 172.312 | Liquid hazardous materials in non-bulk packagings |