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Interpretation Response #13-0163 ([Green Bay Packaging Inc. – Fremont Divisio] [Mr. Lance Lycourt])

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

Interpretation Response Details

Response Publish Date:

Company Name: Green Bay Packaging Inc. – Fremont Divisio

Individual Name: Mr. Lance Lycourt

Location State: OH Country: US

View the Interpretation Document

Response text:

December 3, 2013

Mr. Lance Lycourt
Territory Manager
Green Bay Packaging Inc. – Fremont Division
2323 Commerce Drive, Box 650
Fremont, OH 43420-0650

Ref. No.: 13-0163

Dear Mr. Lycourt:

This is in response to your August 6, 2013 email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the marking of packages containing hazardous materials in limited quantities.  You provide diagrams of a particular box and contend that due to the size of the box, and the display of other information and marks, the limited quantity marking can only be applied to the sides, where there is insufficient space for the 100 mm by 100 mm marking required by § 172.315(a).   You ask whether, due to the space limitations, a reduced size (50 mm by 50 mm) limited quantity marking would be in compliance with the requirements of § 172.315(a).   
Section 172.315(a) requires the limited quantity marking to be of a size relative to the package and readily visible.  The minimum dimensions of the square-on-point marking must be 100 mm on each side unless the packaging size requires a reduced size marking that must be no less than 50 mm on each side.  After reviewing the diagrams accompanying your email, it is our opinion that the reduced size markings displayed on the box are not in compliance with § 172.315(a).  A reduced size marking is only authorized if it is necessary due to the size of the packaging.  Only one limited quantity marking is required and the box is of ample size and there is ample space on the box to apply a full size (100 mm by 100 mm) marking.

In accordance with §§ 172.315(a) and 173.25(a) respectively, the depicted proper shipping name (hypochlorite solution) and OVERPACK markings are not required on a package that is marked with the limited quantity marking.  The elimination of these marking elements from one side of the box could provide the additional space needed to apply a full size (100 mm by 100 mm) limited quantity marking.  In addition, there appears to be sufficient space on either of the main faces of the box to apply a full size limited quantity marking.

I trust this information is helpful.  If you have further questions, please do not hesitate to contact this office.


Duane A. Pfund
International Standards Coordinator
Standards and Rulemaking Division

172.315, 173.25

Regulation Sections

Section Subject
172.315 Limited quantities
173.25 Authorized packagings and overpacks