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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #10-0149 ([Minnesota Department of Transportation] [Mr. Mike Ritchie])

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

Interpretation Response Details

Response Publish Date:

Company Name: Minnesota Department of Transportation

Individual Name: Mr. Mike Ritchie

Location State: MN Country: US

View the Interpretation Document

Response text:

September 3, 2010



Mr. Mike Ritchie

Hazardous Materials Specialist

Minnesota Department of Transportation

395 John Ireland Boulevard, Mail Stop 460

St. Paul, MN 55155

Ref. No. 10-0149

Dear Mr. Ritchie:

This responds to your July 16, 2010 letter requesting clarification of the overpack marking and labeling requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if clear shrink wrapped pallets must be marked on the outside with the required package markings (e.g., proper shipping name, identification number, orientation arrows, and "OVERPACK") when the markings on individual packages are not visible because of the package configuration, but markings and labels representative of each hazardous material are visible from the outside of the overpack. Your areas of concern are restated and answered as follows:

Labels and Proper Shipping Name/Identification Number Markings

Section 173.25(a)(2) requires the overpack to be marked with the proper shipping name and identification number, and labeled for each hazardous material contained therein, unless markings and labels representative of each hazardous material in the overpack are visible. For example, an overpack need not be marked and labeled if the markings (i.e., proper shipping name and identification number) and labels on an individual package inside the overpack are not visible but the same markings (i.e., proper shipping name and identification number) and labels representative of that package are clearly visible from the outside on another package contained in that overpack.

Orientation Arrow Marking

Section 173.25(a)(3) requires an overpack containing packages subject to the orientation arrow marking requirements of § 172.312 to be marked with orientation arrows on two opposite vertical sides of the overpack. This requirement is in addition to the orientation arrows displayed on the individual packages.

"OVERPACK" Marking

Section 173.25(a)(4) requires an overpack to be marked "OVERPACK" when specification packagings are required, unless specification markings on the inside packages are visible. The "OVERPACK" marking is not required if the overpack contains multiple packages with

identical package specification markings provided package specification markings representative of each package specification contained in the overpack are visible from the outside.

I hope this information is helpful. If you have further questions, please contact this office.


Ben Supko

Acting Chief, Standards Development

Office of Hazardous Materials Standards


Regulation Sections

Section Subject
172.312 Liquid hazardous materials in non-bulk packagings
173.25 Authorized packagings and overpacks