Interpretation Response #17-0001
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
April 25, 2017
Outbound Logistics Manager
5875 West Van Horn Tavern Road
Columbia, MO 65203
Reference No. 17-0001
Dear Mr. Spears:
This letter is in response to your January 3, 2017, e-mail and letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the general marking requirements for non-bulk packages. You included with your letter pictures illustrating the current marking, which is displayed as "Primers Cap Type UN# 0044 1.4S," on your fiberboard package. Specifically, you ask whether your mark complies with the marking and height requirements of § 172.301(a).
We have paraphrased and answered your questions as follows:
Q1. You ask if the "#" symbol may be displayed after the marking "UN" and before the "identification number" on your fiberboard package.
A1. The answer is no. The "#" symbol is not part of the identification number as shown in § 172.101 of the Hazardous Materials Table (HMT). According to § 172.301(a), non-bulk packagings must be marked with the proper shipping name and identification number (preceded by "UN," "NA," or "ID") as shown in the HMT. Furthermore, the hazard classification information displayed on a non-bulk package must comply with applicable labeling requirements in accordance with § 172.411 for "Explosives 1.4."
Q2. You ask if the 12 mm minimum height requirement for characters in § 172.301(a) applies to the UN identification number marking.
A2. The answer is yes. The general height requirements state that the UN identification number marking must be displayed with characters at least 12 mm (0.47 inches) high. However, because your packages will be carrying less than 30 kg (66 pounds) maximum net mass of material, the characters for the UN identification number must be at least 6 mm (0.24 inches) high.
Q3. You ask if the characters for the proper shipping name "Primers, Cap Type" should be displayed at least 6 mm high according to § 172.301(a).
A3. The HMR do not specifically prescribe minimum height requirements for the display of the proper shipping name on a non-bulk package. If the package you are preparing will be less than 66 pounds and the UN identification number is displayed with characters at least 6 mm (0.24 inches) high, the proper shipping name may be displayed in the same manner
I hope this information is helpful. Please contact us if we can be of further assistance.
Dirk Der Kinderen
Chief, Standards Development Branch
Standards and Rulemaking Division
172.301(a), 172.101, 172.411
|§ 172.411||EXPLOSIVE 1.1, 1.2, 1.3, 1.4, 1.5 and 1.6 labels, and EXPLOSIVE Subsidiary label|