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.
Sincerely,
Ben Supko
Acting Chief, Standards Development
Office of Hazardous Materials Standards
173.25