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Interpretation Response #04-0222

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

Interpretation Response Details

Response Publish Date: 10-15-2004
Company Name: PPL Susquehanna, LLC    Individual Name: Mr. Michael Micca
Location state: PA    Country: US

View the Interpretation Document

Response text:

Oct 15, 2004


Mr. Michael Micca                Reference No. 04-0222
PPL Susquehanna, LLC
769 Salem Blvd.
Berwick, PA 18655

Dear Mr. Micca:

This is in response to your September 23, 2004 letter requesting clarification regarding the marking requirements for empty Class 7 radioactive materials packaging under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). In your scenario, you describe your packaging as one that meets the “empty” requirements for radioactive materials as specified in § 173.428. This section was modified under Docket HM-230 (69 FR 3632; January 26, 2004), effective October 1, 2004. Specifically, you ask if you need to remove, cover, or obliterate both the hazard communication markings (Part 172, Subpart E) and the specification package marking (“USA DOT 7A Type A”) on your package to remain in compliance with § 173.428.

Based on the information provided, if the package is prepared in accordance with § 173.428 (that is, it meets the packaging, definition, and EMPTY labeling requirements specified in that section), then all other hazard communication markings required by the HMR for this material should be removed or covered during transportation. However, § 173.428 requires the identification number for the material to remain on the packaging as specified under § 173.422(a). In addition, the specification marking “USA DOT 7A Type A,” as required under § 178.3 50(b) should remain on the packaging, unless, for some reason, the packaging no longer conforms to the Part 178 specification requirements.

I hope this information is helpful. Please contact us if you require additional assistance.



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


Regulation Sections

Section Subject
§ 173.428 Empty Class 7 (radioactive) materials packaging