Interpretation Response #08-0092
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
May 23, 2008
Mr. Kelly V. Camp
Woodard and Curran, Inc.
95 Cedar Street, Suite 100
Providence, RI 02903
Ref. No. 08-0092
Dear Mr. Camp:
This is in response to your request for clarification of the marking requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) for packages containing limited quantities. Specifically, you request confirmation of your understanding that technical names are not required to be marked on packages containing limited quantities if they are marked in accordance with § 172.315.
As specified in § 172.315, except for transportation by aircraft or if otherwise stated in the HMR, marking the package with the identification number inside a white square on-point configuration identifies the material as a limited quantity and fulfills the general marking requirements in § 172.301(a)(1). If you use this option to identify a package containing a limited quantity, you are not required to mark the shipping name or technical name on the package. If you choose to mark the package with the shipping name, then a technical name may be added, but, provided the requirements of § 172.315 are met, the technical name is not required.
I hope this information is helpful. Please contact this office should you have additional questions.
Hattie L. Mitchell
Chief, Regulatory Review and Reinvention
Office of Hazardous Materials Standards