Interpretation Response #11-0051 ([Reckitt Benckiser, Inc.] [Mr. Richard Hessen])

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

Interpretation Response Details

Response Publish Date: 03/29/2011

Company Name: Reckitt Benckiser, Inc.

Individual Name: Mr. Richard Hessen

Location State: NJ Country: US

View the Interpretation Document

Response text:

March 29, 2011

Mr. Richard Hessen

Reckitt Benckiser, Inc.

399 Interpace Parkway

Parsippany, NJ 07054-0225

Ref. No. 11-0051

Dear Mr. Hessen:

This responds to your February 11, 2011 request for clarification on the new limited quantity marking and the size requirements regarding reduction to 50 mm in size in § 172.315(a)(1) of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if the reduction to 50 mm and placement of the limited quantity marking on the lip of the corrugated shrink wrapped tray is a proper and acceptable application of the marking.

The answer is yes. A final rule under Docket HM-215K was published in the Federal Register on January 19, 2011 (76 FR 3308). In the final rule PHMSA revised the limited quantity marking requirements in § 172.315(a)(1) to allow a 50 mm limited quantity marking. The reduced sized limited quantity marking may be placed on the lip of the tray corrugate, provided the tray corrugate is visible through the shrink wrap. Section 172.315(a)(1) requires the limited quantity marking to be durable, legible and of a size relative to the package that is readily visible. The marking must be applied on at least one side or one end of the outer packaging. The width of the border forming the square on point must be at least 2 mm and the minimum dimension of each side must be 100 mm unless the package size requires a reduced marking that must be no less than 50 mm on each side.

I hope this answers your inquiry. If you need additional assistance, please contact this office at (202) 366-8553.

Sincerely,

Ben Supko

Acting Chief, Standards Development Branch

Standards and Rulemaking Division

172.315(a)(1)

Regulation Sections