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Interpretation Response #99-0064 ([Avonite, Inc.] [Mr. Gilbert G. Espinoza])

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

Interpretation Response Details

Response Publish Date:

Company Name: Avonite, Inc.

Individual Name: Mr. Gilbert G. Espinoza

Location State: NM Country: US

View the Interpretation Document

Response text:

July 27, 1999


Mr. Gilbert G. Espinoza                            Ref No. 99-0064
Avonite, Inc.
1945 Hwy 304
Belen, NM 87002

Dear Mr. Espinoza:

This is in response to your letter dated April 8, 1998, regarding dual markings on packages containing hazardous materials described as "Consumer Commodity, ORM-D" under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  You requested our review of an enclosed drawing showing a package marked with "CONSUMER COMMODITY, ORM-D", "CONSUMER COMMODITY, ORM-D-AIR, "CONSUMER COMMODITY, ID 8000," and bearing a CLASS 9 label.  The package is intended for transportation by highway, air, or vessel.

The HMR do not prohibit more than one marking on packages containing hazardous materials.  So as not to reduce the effectiveness of these markings, we suggest that the markings be placed on opposite sides of the package.  However, the orientation arrows depicted in your drawing do not conform pictorially to the ISO Standard 780-1985, as prescribed in 49 CFR 172.312.

For your information, if all inner packagings meet 49 CFR 173.27, packages intended for materials described as "Consumer commodities, ORM-D," may be marked "ORM-D-AIR regardless of whether they are transported by aircraft (See 49 CFR 172.316(a)(1) and 49 CFR 173.27).

I hope this satisfies 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