Interpretation Response #22-0072
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
January 19, 2023
Ms. Janice Hayes
Logistics Customer Service Manager
Coty Riverside Distribution Center
4608 Appliance Drive
Belcamp, MD 21017
Reference No. 22-0072
Dear Ms. Hayes:
This letter is in response to your June 28, 2022, letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to labeling shipments of limited quantities. In your letter, you provided pictures of a limited quantity package that has the limited quantity marking reproduced on multiple sides of the package. You note that in some instances, one of the limited quantity markings may be covered by a shipping label; however, the remaining limited quantity markings remain visible on the package. You ask whether this situation is permissible, i.e., to possibly cover up one of the limited quantity markings on the package, provided at least one other limited quantity marking is visible on the package.
Based on the description and photographs provided in your letter, the answer is yes. Section 172.315(a)(2) states that the limited quantity square-on-point marking "must be durable, legible, and of a size relative to the packaging, readily visible, and must be applied on at least one side or one end of the outer packaging." The HMR do not prohibit the placing of multiple limited quantity markings on a package, such as depicted in your photographs, provided the applicable requirements in § 172.315 are met. However, it is the opinion of this Office that a partially-obscured limited quantity marking—as pictured in your incoming letter—should be covered to avoid frustration of your shipment during transportation.
I hope this information is helpful. Please contact us if we can be of further assistance.
T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division
|§ 172.315||Limited quantities|