Interpretation Response #12-0173 ([HMT Associates, L.L.C.] [Mr. E. A. Altemos])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: HMT Associates, L.L.C.
Individual Name: Mr. E. A. Altemos
Location State: VA Country: US
View the Interpretation Document
Response text:
This responds to your August 8, 2012 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the display of limited quantity package marking. Specifically, you describe and provide photographs of the following two scenarios and ask whether they conform to the marking display requirements as prescribed in § 172.315 of the HMR:
Scenario 1: A reduced-size limited quantity marking of at least 50 mm but less than 100 mm on each side is displayed in a square-on-point configuration as authorized by § 172.315. The marking is durable, legible, and readily visible. Is this scenario in accordance with the HMR?
Answer 1: The answer is yes. As authorized in § 172.315, a reduced-size marking between 50 mm and 100 mm may be used in place of a corresponding marking that otherwise conforms to the requirements of the HMR, which permit use of a reduced-size hazard marking when a package surface is too small or of an irregular shape for a full size marking.
Scenario 2: A limited quantity marking of 100 mm on each side is displayed in a square-on-side configuration. The marking is durable, legible, and readily visible. Is this scenario in accordance with the HMR?
Answer 2: The answer is yes. The HMR do not prohibit the placement of a limited quantity marking in an orientation where the square-on-point is located with its flat sides parallel to the sides of the packages. A limited quantity marking that otherwise conforms to the requirements of the HMR may be placed square-on-side when the square-on-point is not practicable if the package surface is too small or of an irregular shape for a full size marking. However, the square-on-point configuration is the preferred (recommended) method for displaying the limited quantity marking required by the HMR.
I trust this satisfies your inquiry. Please contact us if we can be of further assistance.
Sincerely,
T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division
172.315
Regulation Sections
| Section | Subject |
|---|---|
| 172.315 | Limited quantities |