Interpretation Response #07-0135 ([OUHSC Nuclear Pharmacy] [Mr. Michael W. Sullens B.S., D.PH.])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: OUHSC Nuclear Pharmacy
Individual Name: Mr. Michael W. Sullens B.S., D.PH.
Location State: OK Country: US
View the Interpretation Document
Response text:
Nov 15, 2007
Mr. Michael W. Sullens B.S., D.PH. Ref. No. 07-0135
Manager, OUHSC Nuclear Pharmacy
1110 N. Stonewall Ave., Rm. 139
Oklahoma City, OK 73117
Dear Mr. Sullens:
This responds to your letter regarding package marking requirements prescribed in § 178.3(a)(4) of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).
You state that, as a Nuclear Pharmacy, your question applies to liquid-filled syringes containing radioactive medical injections. The packages are capable of holding a maximum of 10 syringes, each syringe having a maximum capacity of 5 ml, and the maximum overall liquid capacity is 50 ml. Each syringe is encased in an individual lead-lined syringe holder, which the package is designed to hold. A fully loaded package weighs over 5 kg. You asked what size marking is required to be placed on the package described above.
Each specification or UN standard package must be marked in accordance with § 178.3(a)(4). The letters and numerals representing the markings must be at least 12.0 mm (0.47 inches) in height. For packages smaller than or equal to 30 L (7.9 gallons) capacity for liquids or 30 kg (66 pounds) for solids, the height must be at least 6.0 mm (0.2 inches). For packages having a capacity of 5 L (1 gallon) or 5 kg (11 pounds) or less, letters and numerals must be of an appropriate size. For a combination packaging, § 178.503 specifies marking the maximum gross mass in kilograms. If the gross mass is 5 kg or more, up to 30 kg, § 178.3 requires markings of at least 6.0 mm.
I hope this satisfies your inquiry. If we can be of further assistance, please contact us.
Sincerely,
John A. Gale
Chief, Standards Development
Office of Hazardous Materials Standards
178.3(a)(4)