Interpretation Response #24-0027
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: BASF Corporation
Individual Name: Benjamin Frankowski
Location State: NC Country: US
View the Interpretation Document
Response text:
July 16, 2024
Benjamin Frankowski
Senior Packaging Engineer
Agricultural Solutions North America (N-APN/PP)
BASF Corporation
2 TW Alexander Drive
Research Triangle Park, NC 27709
Reference No. 24-0027
Dear Mr. Frankowski:
This letter is in response to your April 17, 2024, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the size of a specification marking for a combination packaging that is comprised of multiple inner packagings (plastic jerricans (3H1)) and an outer packaging (fiberboard box (4G)). You state that the outer packaging has a cubic volume that is greater than 30 L and the combined volume of the inner packaging(s) is less than 30 L. Specifically, you ask whether the minimum required size of a United Nations (UN) specification marking—as specified in § 178.3(a)(4)—is based on the volume of the outer packaging or that of the combined volume of the inner packaging(s).
For combination packagings, the minimum size standard for letters and numerals that make up the specification marking applies to the capacity of the outer packaging. Note that this applies regardless of whether the inner packagings used in the combination packaging are also UN specification packagings or whether the combined capacity of the inner packagings is less than 30 L. Thus, based on the size of the outer packaging you indicated, the specification marking must be at least 12.0 mm (0.47 inches) in height.
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
178.3(a)(4)
Regulation Sections
| Section | Subject |
|---|---|
| 178.3 | Marking of packagings |