Interpretation Response #06-0022
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Jun 16, 2006
Mr. Steven T. Webb
Reference No. 06-0022
U.S. Coast Guard CITAT
6500 South Macarthur Boulevard
Oklahoma City, OK 73169
Dear Mr. Webb:
This is in response to your request for a clarification of the marking requirements for limited quantities prescribed in § 172.3 15 of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). We have paraphrased your questions and answered them in the order provided. We apologize for the delay in responding and any inconvenience this may have caused.
Q1. Is the marking the International Maritime Dangerous Goods Code (IMDG) requires for limited quantity shipments under Section 188.8.131.52.2, i.e., the UN identification number for the material in a white square-on-point diamond, unless excepted under Section 3.4.7, the same as that required for limited quantity shipments under § 172.3l5 of the HMR ?
Al. Yes. As specified in § 172.3 15, except for transportation by aircraft, marking the package with the identification number inside a white square-on-point configuration identifies the material as a limited quantity and fulfills the requirements of § 172.301(a)(1). If a shipper uses this method to identify packages containing limited quantities, the shipper is not required to mark the proper shipping name, technical name, hazardous substance name(s) or "RQ" on the outer package.
Q2. If the shipper marks the package with the proper shipping name and UN identification number, is the shipper also required to mark the package with the UN identification within the white square-on-point diamond?
A2. No. If a shipper does not use the UN identification within the "white square-on- point diamond" exception, the outer package for a limited quantity must comply with marking requirements for non-bulk packages prescribed in § 172.301, and other applicable requirements in 49 CFR Part 172, Subpart D, for the hazard class(es) contained within the package.
I hope this information is helpful.
Hattie L. Mitchell, Chief
Regulatory Review and Reinvention
Office of Hazardous Materials Standards
|§ 172.315||Limited quantities|