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Interpretation Response #07-0079 ([National Institute of Standards and Technology] [Mr. Larry Lucas ])

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

Interpretation Response Details

Response Publish Date:

Company Name: National Institute of Standards and Technology

Individual Name: Mr. Larry Lucas 

Location State: MD Country: US

View the Interpretation Document

Response text:

Jun 12, 2007


Mr. Larry Lucas                Reference No. 07-0079
National Institute of Standards and Technology
100 Bureau Drive
Stop 8462
Gaithersburg, MD 20899-8462

Dear Mr. Lucas:

This is in response to your April 20, 2007 letter regarding subsidiary labeling requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if a subsidiary hazard label is required for a package the meets the definition of a Class 7 (Radioactive) material and also meets the definition of a Class 8 (Corrosive) material. The material in question is a solution of radioactive isotopes requiring a Class 7 hazard label (typically Yellow-II), and 5 milliliters (<1/5 ounce) of a Class 8 acid.

Section 172.402(d) requires each package containing a Class 7 (Radioactive) material that also meets the definition of one or more additional hazard classes to be labeled as a Class 7 (Radioactive) material, as required by § 172.403, and for each additional hazard. However, an exception from the subsidiary labeling requirement is provided in § 172.402(d)(1) when the material satisfies the requirements of § 173.4 (small quantity exception).

I hope this information is helpful. If you have further questions, please do not hesitate to contact this office.



John A. Gale
Chief, Standards Development
Office of Hazardous Materials Standards

172.402 (d), 173.4

Regulation Sections

Section Subject
172.402 Additional labeling requirements
173.4 Small quantities for highway and rail