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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #98-0307 ([Rapid Aid] [Ms. Sally Hamam])

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

Interpretation Response Details

Response Publish Date:

Company Name: Rapid Aid

Individual Name: Ms. Sally Hamam

Country: CA

View the Interpretation Document

Response text:

DEC 16, 1998


Ms. Sally Hamam                      Ref. No. 98-0307

Rapid Aid

1-3345 Laird Road

Mississauga, Ontario L5L 5R6

Dear Ms. Harnam:

This is in response to your letter dated October 5, 1998, requesting clarification on the marking requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you are requesting confirmation that your Rapid Aid Cold Pack Instant Cold Compress packaging is properly marked.

According to your letter and enclosed inner packaging for your cold pack product, you are describing the contents as: Ammonium nitrate fertilizer crystals, NA-2072 and water. Under § 172.301 a non­bulk packaging must be marked with the proper shipping name and identification number (preceded by "UN" or "NA", as appropriate) for the material as shown in the Hazardous Materials Table in § 172.101. However, identification numbers are not required on packages which contain only limited quantities, as defined in § 171.8, or for ORM-D materials, such as consumer commodities. These required markings must be placed on the outside package, not on the inner packagings such as your plastic cold pack bags.

It is the opinion of this Office that your cold packs qualify for the limited quantity exception in § 173.152 and meet the definition of a consumer commodity. Each inner packaging may not exceed 2.2 pounds for oxidizers in Packing Group IT and 11 pounds for oxidizers in Packing Group ID. The gross weight of the package may not exceed 66 pounds. Therefore, your package may be marked with the proper shipping name, "Consumer Commodity", and with the ORM-D marking as specified in § 172.316.

I hope this answers your inquiry.



Delmer F. Billings

Chief, Standards Development

Office of Hazardous Materials Standards


Regulation Sections

Section Subject
172.301 General marking requirements for non-bulk packagings