Interpretation Response #11-0212
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name:
Individual Name:
Location State: GA Country: US
View the Interpretation Document
Response text:
February 16, 2012
Mr. Carl Bollinger
Zyvax Corporate
15412 Highway 515 S
Ellijay, GA 30536
Reference No.: 11-0212
Dear Mr. Bollinger:
This is in response to your August 26, 2011 e-mail to the Hazardous Materials Information Center and follow-up telephone discussion requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) as they pertain to the overpack marking requirement of §173.25(a)(4). You ask whether a box marked "OverPack" is acceptable to meet the "OVERPACK" mark specified by §173.25(a)(4).
In addition to the HMR, the requirement for the overpack marking is also found in the international standards and regulations, including the United Nations Recommendations on the Transport of Dangerous Goods (UN Model Regulations); the International Civil Aviation Organization's Technical Instructions for the Safe Transport of Dangerous Goods by Air (ICAO Technical Instructions); and the International Maritime Dangerous Goods Code (IMDG Code). It is also under proposal for Transport Canada"s Transportation of Dangerous Goods Regulations (Transport Canada TDG). The HMR, UN Model Regulations, IMDG Code, and proposed Transport Canada TDG standards are all consistent in specifying the "OVERPACK" marking. The only variation from this requirement is the ICAO Technical Instructions standard that specifies an "Overpack" marking.
The "OverPack" marking that you reference is not consistent with any of the existing or proposed standards and regulations and is therefore not acceptable to meet the requirements of §173.25(a)(4) of the HMR.
I hope this satisfies your inquiry. Please contact us if we can be of further assistance.
Sincerely,
Delmer Billings
Senior Regulatory Advisor
Standards and Rulemaking Division
173.25(a)(4)
Regulation Sections
| Section | Subject |
|---|---|
| 173.25 | Authorized packagings and overpacks |