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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 #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.



Delmer Billings
Senior Regulatory Advisor
Standards and Rulemaking Division


Regulation Sections

Section Subject
173.25 Authorized packagings and overpacks