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Interpretation Response #14-0228 ([URS Corporation] [Mr. Andrew Romach])

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

Interpretation Response Details

Response Publish Date:

Company Name: URS Corporation

Individual Name: Mr. Andrew Romach

Location State: NC Country: US

View the Interpretation Document

Response text:

January 16, 2015

Mr. Andrew Romach
Regulatory Compliance Manager
URS Corporation
1600 Perimeter Park Drive
Morrisville, NC 27560

Reference No. 14-0228

Dear Mr. Romach:

This is in response to your November 19, 2014 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the proper shipping name marking size for IBCs that are labeled instead of placarded.  Specifically, in the case of an IBC labeled in accordance with § 172.514(c), you ask if a proper shipping name with a height of 6 mm and a UN identification number with a height of 12 mm displayed adjacent to the hazard label is authorized.  

The answer is yes.  Section 172.336(d) provides a special provision for the display of identification numbers that permits a bulk packaging that is labeled instead of placarded in accordance with 172.514(c) to display identification number markings consistent with the requirements of § 172.301(a)(1).  Section 172.301(a)(1) prescribes a 12 mm minimum height requirement for the identification number for an IBC; however, a minimum height for the proper shipping name is not prescribed.  In addition, a transitional exception provided in § 172.301(a)(1)(i) prescribes that for domestic transportation, until January 1, 2017, identification number markings are not subject to the 12 mm minimum height requirement.

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


Shane C. Kelley
Acting International Standards Coordinator
Standards and Rulemaking Division

172.514(c), 172.336(d), 172.514(c), 172.301(a)(1),  172.301(a)(1)(i)   

Regulation Sections

Section Subject
172.301 General marking requirements for non-bulk packagings
172.301 General marking requirements for non-bulk packagings
172.336 Identification numbers; special provisions
172.514 Bulk packagings
172.514 Bulk packagings