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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 #10-0185 ([FedEx Custom Critical] [Ms. Kellie Toth])

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

Interpretation Response Details

Response Publish Date:

Company Name: FedEx Custom Critical

Individual Name: Ms. Kellie Toth

Location State: OH Country: US

View the Interpretation Document

Response text:

December 15, 2010



Ms. Kellie Toth

FedEx Custom Critical

1475 Boettler Rd

Uniontown, OH 44685

Ref. No.: 10-0185

Dear Ms. Toth:

This responds to your letter regarding the large quantities marking requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180), as they apply to highway transportation of a material described as "UN1791 Hypochlorite Solutions, 8, II", Ltd Qty. In your letter you indicate that the material is packaged in 490 boxes, 5880 liters, totaling 15,680 pounds. You state that each box is marked with the UN identification number and the proper shipping name. Specifically, you ask if the transport vehicle must be marked in accordance with § 172.301(a)(3).

Section §172.301(a)(3) states that a transport vehicle or freight container containing only a single hazardous material in non-bulk packages must be marked with the identification number specified for the material, subject to the following provisions and limitations:

(1) Each package is marked with the same proper shipping name and identification number;

(2) The aggregate gross weight of the hazardous material is 4,000 kg (8,820 pounds) or more;

(3) All of the hazardous material is loaded at one loading facility;

(4) The transport vehicle or freight container contains no other material, hazardous or otherwise; and

(5) These requirements do not apply to Class 1, Class 7, or to non-bulk packagings for which identification numbers are not required.

However, § 172.301(a) indicates that identification numbers are not required on packagings that contain only ORM-D materials or limited quantities, except for limited quantities marked in accordance with § 172.315. Also, § 172.315 indicates that a proper shipping name is not required to be marked on a package containing a limited quantity when the package is marked with an identification number displayed inside a white square-on-point configuration. This marking is optional and may be used in lieu of the marking requirements prescribed in § 172.301(a)(1).

Based on these exceptions from marking the identification number on the package, it is the opinion of this Division that the large quantities marking requirements in § 172.301(a)(3) do not apply to limited quantities excepted from the identification number marking requirements.

I hope this information is helpful. If we can be of further assistance, please contact us.


Ben Supko

Acting Chief, Standards Development

Standards and Rulemaking Division

172.301(a)(3), 172.315

Regulation Sections

Section Subject
172.301 General marking requirements for non-bulk packagings