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Interpretation Response #17-0079


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

Interpretation Response Details

Response Publish Date: 03-16-2018
Company Name: QSA Global, Inc    Individual Name: Ms. Lori Podolak
Location state: MA    Country: US

View the Interpretation Document


Response text:

March 6, 2018

Lori Podolak
Senior RA/QA Specialist
QSA Global, Inc.
40 North Avenue
Burlington, MA 01803

Reference No. 17-0079

Dear Ms. Podolak:

This letter is in response to your July 6, 2017, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the marking of U.S. Department of Transportation (DOT) Specification 7A packagings. You state § 178.350(b) specifies that packaging conforming to DOT Specification 7A criteria must be marked with "USA DOT 7A Type A" and "Radioactive Material." You include in your email a picture of a marking that indicates the proper shipping name, the specification packaging type, and the country of origin; however, the words "Type A Package" are placed in conjunction with the proper shipping name as opposed to being in line with the packaging specification. Specifically, you ask whether it is acceptable to mark a DOT Specification 7A package in a sequence other than that which appears in the HMR.

The answer is no. "USA DOT 7A Type A" is a given packaging specification that is required to be marked in accordance with § 178.350(b). The HMR do not permit deviation in words or sequence from that which appears in quotation marks. Additionally, note that the words "Radioactive Material" are no longer required as part of the specification marking. The January 26, 2004, final rule titled "Hazardous Materials Regulations: Compatibility with the Regulations of the International Atomic Energy Agency" (HM-230; 69 FR 3632) removed this requirement since those words appear as part of the proper shipping name (PSN) for all radioactive materials.

I hope this information is helpful. Please contact us if we can be of further assistance.

Sincerely,

Dirk Der Kinderen
Chief, Standards Development Branch
Standards and Rulemaking Division

178.350(b)


Regulation Sections

Section Subject
§ 178.350 Specification 7A; general packaging, Type A.