Interpretation Response #16-0104 ([Ms. Amanda Hammon])
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: Ms. Amanda Hammon
Location State: FL Country: US
View the Interpretation Document
Response text:
August 22, 2016
Ms. Amanda Hammon
Product Safety Representative
1144 East Newport Center Drive
Deerfield Beach, FL 33442
Reference No. 16-0104
Dear Ms. Hammon:
This letter is in response to your June 9, 2016, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to voluntary information describing a hazardous material on shipping papers and package markings. We have paraphrased and answered your questions as follows:
Q1. You ask whether materials properly classified as identification number “UN1133” may be described with both “Adhesives” and “Adhesives, containing a flammable liquid” as the proper shipping name for the purposes of shipping papers and package markings.
A1. The answer is yes. In accordance with § 172.101(c)(2), “Punctuation marks and words in italics are not part of the proper shipping name, but may be used in addition to the proper shipping name.” For UN1133, the Hazardous Materials Table (HMT) lists the name “Adhesives” in Roman type as the proper shipping name. The phrase “containing flammable liquid” is in italics and, therefore, may be permissively included as part of the proper shipping name on shipping papers and package markings in accordance with part 172 subparts C and D, respectively.
Q2. You ask whether a technical name may be provided on a shipping paper or package marking in between the proper shipping name and hazard class for HMT entries that do not include a “G” in Column 1.
A2. The answer is yes. Many entries in the HMT do not include a “G” in Column 1 and are not otherwise required to include a technical name on a shipping paper under § 172.203(k). However, a shipper may voluntarily include a technical name on a shipping paper following the basic description or in parenthesis between the proper shipping name and hazard class (see § 172.202(d)).
Section 172.301(b) requires non-bulk packages containing a hazardous material, subject to the provisions of § 172.203(k), to be marked with the technical name. This section prohibits packages containing materials in Division 6.2 from displaying the technical name on the outside of the package. The HMR do not otherwise prohibit technical names from being displayed on the outside of the package.
Q3. You ask whether the hazard class and packing group may be displayed on the outer package following the identification number and proper shipping name in a location near the hazard class label.
A3. The answer is yes. The HMR do not prohibit additional information from being displayed on the outer packaging after the information required by part 172 subpart D, provided the information properly describes the material.
I hope this information is helpful. Please contact us if we can be of further assistance.
Sincerely,
T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division
172.101(c)(2), 172.203(k), 172.202(d), 172.301(b), 172