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Interpretation Response #98-0414 ([Hazmateam, Inc.] [Mr. Leo Traverse])

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

Interpretation Response Details

Response Publish Date:

Company Name: Hazmateam, Inc.

Individual Name: Mr. Leo Traverse

Location State: NH Country: US

View the Interpretation Document

Response text:

APR 2, 1998

 

Mr. Leo Traverse
Hazmateam, Inc.
12 Kimball Hill Road
Hudson, NH 03051-3915

Dear Mr. Traverse:

This is in response to your letter and telephone conversation with a member of my staff concerning the marking and labeling requirements for palletized non-bulk packages containing four different classes of hazardous materials that are overpacked with clear shrink wrap. I apologize for the delay in responding and hope it has not caused any inconvenience.

Your questions are paraphrased and answered as follows:

Q1. If markings and labels on the packages that represent all four hazard classes are visible when viewed from each different side, am I required to mark and label the outside of the shrink wrap?

AI. If each package is properly marked and labeled and if markings and labels
representative of each hazardous material contained within the overpack are visible, the answer is no. The markings and labels are not required to be repeated on the overpack. See 49 CFR 173.25.

Q2. If markings and labels on the packages that represent all four hazard classes are NOT visible when viewed from each different side, am I required to mark and label the outside of the shrink wrap?

A2. Yes. When packages are stacked and banded on a pallet, the packages should be
positioned, when possible, so that the markings and labels are visible on the outside of the stack. If markings and labels representative of each hazardous material in the overpack are not visible from any side, the overpack must be marked and labeled for that hazardous material. As an example, iffaur packages of Acetone, 3, UN1090, are loaded next to other packages so that their markings and labels are not visible, the proper shipping name, identification number, and a Class 3 label for the Acetone must be displayed on one side or end of the overpack, except that duplicate labeling must be displayed on at least two sides or two ends (other than the bottom) of each overpack having a volume of 1.8 cubic meters (64 cubic feet) or more. See § 172.406(e).

I hope this information is helpful. Ifwe can assist you further, please contact us.

Sincerely,

 

Hattie L. Mitchell, Chief
Regulatory Review and Reinvention
Office of Hazardous Materials Standards

172.400, 173.25

Regulation Sections

Section Subject
172.400 General labeling requirements
173.25 Authorized packagings and overpacks