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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 #98-0330 ([Mainstream Engineering Corp.] [Mr. Lawrence R. Grzyll])

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

Interpretation Response Details

Response Publish Date:

Company Name: Mainstream Engineering Corp.

Individual Name: Mr. Lawrence R. Grzyll

Location State: FL Country: US

View the Interpretation Document

Response text:

FEB 16, 1999


Mr. Lawrence R. Grzyll                       Ref. No. 98-0330
Mainstream Engineering Corp.
Pines Industrial Center
200 Yellow Place
Rockledge, FL 32955

Dear Mr. Grzyll:

This is in response to your letter dated October 27, 1998, regarding marking and labeling requirements for overpacks under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  In your letter you stated that you,are shipping one hazardous material under the small quantity exception provided in § 173.4 and another hazardous material under, the terms of exemption DOT-E-10232.    Specifically you ask if it is, permissible to overpack these packages together and if so what markings and labels are required.on overpacks.

Authorized packages containing hazardous materials may be offered for transportation in an overpack, if all the conditions in § 173.25 are met.  An overpack, as defined in § 171.8, is an enclosure used by a single consignor to provide protection or convenience in handling of a package or to consolidate two or more packages (i.e., a protective outer packaging such as a box or crate, or secured to a pallet by shrinkwrapping, strapping, etc.).

Each inner package must be marked and labeled in accordance with the HMR.  In addition, each overpack must be marked with the proper shipping name and identification number, and labeled for each hazardous material it contains.  The overpack must also be marked with a statement indicating that inside (inner) packages comply with prescribed specifications when specification packagings are required, unless the specification markings on the inside packagings are visible.

However, an overpack is not required to be marked with the proper shipping name and identification number, or labeled for any hazardous material packaged in accordance with § 173.4.

I hope this satisfies your request.



John A. Gale
Transportation Regulations Specialist
Office of Hazardous Materials Standards


Regulation Sections

Section Subject
173.25 Authorized packagings and overpacks