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Interpretation Response #14-0195 ([The Clorox Company] [Mr. Maurice C. Carson])

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

Interpretation Response Details

Response Publish Date:

Company Name: The Clorox Company

Individual Name: Mr. Maurice C. Carson

Location State: GA Country: US

View the Interpretation Document

Response text:

April 02, 2015

Mr. Maurice C. Carson
Hazardous Materials Transportation Specialist
The Clorox Company
1000 Cobb Place Boulevard NW, Suite 100
Kennesaw, GA 30144

Reference No. 14-0195

Dear Mr. Carson:

This is in response to your recent letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180), and your October 14, 2014, conversation with a member of our Hazardous Materials Information Center staff, applicable to the limited quantity marking prescribed in §172.315.

In your letter, you state that your company places bleach products in packages that comply with §173.156 on a pallet, and then surrounds these packages in a shrink-wrap overpack. You also state your company places the §172.315 limited quantity marking only on the outer surface of the shrink wrap. Further, you state your company was cited for not placing the limited quantity mark on each package that complied with §173.156. You ask if the HMR require this mark to be placed on the outer surface of each limited quantity package that is transported internationally by vessel.

For those bleach products that meet the definition of a hazardous material and comply with the HMR's limited quantity regulations, the answer is yes. The HMR require markings prescribed in 49 CFR Part 172, Subpart D, which includes the §172.315 limited quantity marking, to be printed on or affixed to the surface of a completed package that contains a hazardous material (see §172.304(a)(1)). In your example, the completed package is the box of hazardous material bleach products that complies with §173.156, and the overpack is the shrink wrap (see the definitions for "package" and "overpack" in §171.8). If the markings the HMR require are visible through the shrink wrap, they are not required to be repeated on the outer surface of the overpack (see §173.25(a)(2)).

I hope this satisfies your request.


T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division

172.315, 173.156, 172.304(a)(1), 171.8, 173.25(a)(2)

Regulation Sections

Section Subject
171.8 Definitions and abbreviations
172.304 Marking requirements
172.315 Limited quantities
173.156 Exceptions for limited quantity and ORM
173.25 Authorized packagings and overpacks