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Interpretation Response #07-0060 ([Sandia National Laboratories] [Mr. Leighton Ford])

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

Interpretation Response Details

Response Publish Date:

Company Name: Sandia National Laboratories

Individual Name: Mr. Leighton Ford

Location State: CA Country: US

View the Interpretation Document

Response text:

Apr 16, 2007


Mr. Leighton Ford                Reference No. 07-0060
Sandia National Laboratories
Environmental Management Department
7011 East Avenue MS 9221
Livermore, CA 94550

Dear Mr. Ford:

This responds to your letter dated March 13, 2007, regarding display of the UN marking or symbol on packagings (e.g. UN standard or specification drums) in accordance with the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Your questions are paraphrased and answered as follows:

Q.        Section 178.503(a)(1) permits the letters “UN” to be applied in place of the symbol; however, the regulations do not specifically state that the upper case “UN” letters may be used in the symbol. Is there any distinction between using upper case “UN” letters vs. lower case “un” letters in the symbol or in place of the symbol as allowed by § 178.503(a)(l)?

A.        The answer is yes. The design of the United Nations’ symbol is distinctive and allows the United Nations’ symbol to be read the same regardless of orientation (upside down or right side up) on the package. A packaging conforming to a UN standard must be marked with the United Nations’ symbol (i.e., lower case letters within a circle) as illustrated in paragraph (e) of §178.503. For embossed metal receptacles, the letters “UN” may be used in place of the United Nations symbol on a UN standard or specification package.

Q.        Section 178.503(a)(1) requires the side marking and the bottom marking to be the same information as that found on the bottom of the drum (permanently embossed). Do the side marking and bottom marking of the drum in the photographs we submitted meet the specification package marking requirements under the HMR?

A.        The photographs you provided are unclear. The two black and white photographs of the label or sticker of the side markings on the drum, previously e-mailed to us, are clearer; however, the UN symbol on the label or sticker, which must be shown in lower case “un” letters, does not meet the UN standard or specification package marking requirements under the HMR.

UN standard packagings must be marked as specified in § 178.3 and 178.503. As prescribed in § 178.3, for packages with a gross mass of more than 30 kg (66 pounds), the markings must appear on the bottom or the side of the packaging. In accordance with §178.503(a)(1), every new metal drum having a capacity of 100 L must bear the marks described in paragraphs (a)(1) through (a)(6) and (a)(9)(i) in a permanent form on the bottom. The markings on the top, head or side of these packagings need not be permanent.

I hope this information is helpful. If we can be of further assistance, please contact us.



Edward T. Mazzullo
Director, Office of Hazardous
Materials Standards

178.503 (a)(1)

Regulation Sections

Section Subject
178.503 Marking of packagings