Interpretation Response #10-0154 ([HAZMATPAC] [Mr. Donald H. Hausmann])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: HAZMATPAC
Individual Name: Mr. Donald H. Hausmann
Location State: TX Country: US
View the Interpretation Document
Response text:
December 22, 2010
Mr. Donald H. Hausmann
HAZMATPAC
5301 Polk Street, Bldg. 18
Houston, Texas 77023
Ref. No.: 10-0154
Dear Mr. Hausmann:
This responds to your letter regarding the number and type of UN marking which may be placed on a combination packaging, UN4G or UN4GV box, in accordance with the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Your questions are paraphrased and answered as follows:
You provided the following examples:
Example 1: One box tested and marked "UN4GV/X12" and "UN4GY20", containing 4 one liter glass bottles and 8 one quart plastic bottles, respectively.
Example 2: One box tested and marked "UN4G/X35" and "UN4G/Y26", containing one large explosive cartridge and 4 one gallon plastic bottles, respectively.
Example 3: One box tested and marked "UN4G/Y27" and "UN4G/Z37", containing 4 four liter glass bottles.
Example 4: One box tested and marked "UN4G/Y28, "UN4G/X26", UN4GV/X15", and UN4G/Z35, containing 4 one gallon glass bottles, 4 one gallon metal cans, 4 one quart glass bottles and 4 one gallon plastic bottles, respectively.
Example 5: One box tested and marked with eight different markings:
A: "UN4G/X28" and "UN4G/Y42", containing 4 one gallon glass bottles;
B: "UN4G/X26"and "UN4G/Y40", containing 4 one gallon plastic bottles or 4 one quart glass bottles;
C: "UN4GV/X15", containing 4 one quart glass bottles;
D: "UN4GV/X8", containing 4 eight ounce glass bottles; and
E: "UN4G/Y30" and "UN4G/Z45", containing 4 one gallon plastic bottles.
You also asked if the end user would have to cover up the marking that was not used for the respective shipment.
Where a packaging conforms to more than one UN standard or DOT specification, the packaging may bear more than one marking, provided the packaging meets all the requirements of each standard or specification, and documentation must be maintained by the packaging manufacturer. Where more than one marking appears on a packaging, each marking must appear in its entirety. Therefore, multiple package markings are not prohibited on a packaging, such as a UN4G box containing a variety of inner packagings (See §178.3(c)). The conditions for use would have to be clearly set forth in the notification to users required by § 178.2(c). However, to avoid potential confusion and/or possible violation of the HMR, the non-applicable marking should be covered or obliterated during transportation.
I hope this satisfies your inquiry. If we can be of further assistance, please contact us.
Sincerely,
Ben Supko
Acting Chief, Standards Development Branch
Standards and Rulemaking Division
178.3, 178.2