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Interpretation Response #09-0121 ([Grafco, LLC] [Ms. Jan Cowles])

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

Interpretation Response Details

Response Publish Date:

Company Name: Grafco, LLC

Individual Name: Ms. Jan Cowles

Location State: OK Country: US

View the Interpretation Document

Response text:

October 1, 2009




Ms. Jan Cowles

Grafco, LLC

P.O. Box 814

Owasso, OK 74055

Ref. No. 09-0121

Dear Ms. Cowles:

This is in response to your e-mail requesting clarification of marking requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask whether the letters "USP" may be displayed before the proper shipping name on a package or whether a special permit currently authorizes this marking variation to the HMR.

As specified in § 172.301(a), each person who offers a hazardous material for transportation in a non-bulk packaging must mark the package with the proper shipping name and identification number for the material as shown in the Hazardous Materials Table (HMT) in § 172.101. The letters "USP" are not part of the proper shipping name as shown in the HMT and are not authorized to be included as part of the proper shipping name marking. Additional wording, such as "USP," may be included after the required wording (proper shipping name and ID number) provided the additional wording does not reduce the effectiveness of the required information and other specifications for displaying markings (see § 172.304(a)(4)).

The procedure for applying for a special permit can be found in 49 CFR Part 107, Subpart B and can also be found on our website at under "Special Permits." PHMSA has not issued a special permit to authorize the letters "USP" to be displayed before the proper shipping name on packages.

With respect to labeling requirements, it is difficult to determine the specifications of the Class 2 label in the pictorial you submitted, but please note that label specifications, including size, are specified in § 172.407; modifications are specified in § 172.405; and exceptions are specified in § 172.400a. Unless otherwise excepted, packages must be labeled with both the primary and subsidiary hazard labels, as specified in Column 6 of the § 172.101 Hazardous Materials Table. "Oxygen, compressed," UN1072 requires a Division 5.1 subsidiary hazard label (see § 172.402) as well as a Class 2 primary hazard label.

I hope this information is helpful. Please contact this office should you have additional questions.


Hattie L. Mitchell

Chief, Regulatory Review and Reinvention

Office of Hazardous Materials Standards

§ 172.301

Regulation Sections

Section Subject
172.301 General marking requirements for non-bulk packagings